STEPHENS INC.

SEC File No: 801-15510 Stephens Inc. 111 Center Street Little Rock, Arkansas 72201-4430 877-891-0095 Website: www.stephens.com Form ADV: Part 2A March 31, 2025 Uniform Application for Investment Advisor Registration This brochure provides information about the qualifications and business practices of Stephens Inc. If you have any questions about this brochure or its content, please contact us at 877-891-0095 or www.stephens.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Stephens Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. Stephens Inc. is a registered investment adviser with the United States Securities and Exchange Commission. Registration does not imply a certain level of skill or training. ADV Part 2A March 31, 2025 1  Item 2 Material Changes This section identifies and discusses material changes to the Stephens Inc. Form ADV, Part 2A (“Brochure”) since Stephens Inc.’s prior annual updating amendment to the Brochure, which was filed on March 28, 2024. For more details, please see the items in this ADV Brochure referred to in the summary below. Item 14 was updated to disclose: (i) payments employees of Stephens Inc. and its affiliates can receive for referring prospective clients seeking investment advisory services, and (ii) payment Financial Consultants and Investment Advisor Representatives are eligible to receive for making referrals to Stephens Inc.’s Investment Banking division. ADV Part 2A March 31, 2025 2  Item 3 Table of Contents ITEM 2 MATERIAL CHANGES ................................................................................................................................. 2 ITEM 3 TABLE OF CONTENTS ................................................................................................................................. 3 ITEM 4 ADVISORY BUSINESS .................................................................................................................................. 4 A. ADVISORY FIRM AND PRINCIPAL OWNERS ............................................................................................................. 4 B. THE TYPES OF INVESTMENT ADVISORY SERVICES WE PROVIDE ............................................................................ 4 C. ADVISORY SERVICES ............................................................................................................................................... 4 D .WRAP FEE PROGRAMS ............................................................................................................................................ 5 DISCRETIONARY WRAP PROGRAMS ............................................................................................................................. 6 LIMITED-DISCRETIONARY WRAP PROGRAMS ............................................................................................................. 9 NON-DISCRETIONARY WRAP PROGRAMS ..................................................................................................................... 13 RETIREMENT ADVISORY PLATFORMS – NON DISCRETIONARY ...................................................................................... 17 RESEARCH ADVISORY SERVICES .................................................................................................................................. 17 E. ASSETS UNDER MANAGEMENT ............................................................................................................................. 18 ITEM 5 FEES AND COMPENSATION .................................................................................................................... 18 A. OVERVIEW OF FEE ARRANGEMENTS .................................................................................................................... 18 B. PAYMENT OF FEES ................................................................................................................................................ 19 C. OTHER TYPES OF FEES AND EXPENSES CLIENTS MAY PAY ................................................................................. 19 ERISA AND IRA FEES ............................................................................................................................................... 23 ERISA SECTION 408(B)(2) DISCLOSURES.................................................................................................................. 23 PRINCIPAL TRANSACTIONS ........................................................................................................................................ 23 D. PRE-PAID ADVISORY FEES.................................................................................................................................... 26 E. COMPENSATION FOR THE SALE OF SECURITIES AND INVESTMENT PRODUCTS .................................................... 28 ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ........................................... 29 ITEM 7 TYPES OF CLIENTS .................................................................................................................................. 29 ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................ 30 A. METHODS OF ANALYSIS ........................................................................................................................................ 30 B. INVESTMENT STRATEGIES ..................................................................................................................................... 30 C. RISK OF LOSS ........................................................................................................................................................ 30 ITEM 9 DISCIPLINARY INFORMATION .............................................................................................................. 32 ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................. 32 A. OTHER BUSINESS ACTIVITIES ............................................................................................................................... 33 B. STEPHENS INDUSTRY AFFILIATIONS ..................................................................................................................... 33 C. AFFILIATIONS ....................................................................................................................................................... 33 D. ARRANGEMENTS WITH RELATED INVESTMENT ADVISER OR INVESTMENT COMPANIES ...................................... 34 ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ..................................................................................................................................................................... 34 A. INVESTMENT ADVISORY CODE OF ETHICS ........................................................................................................... 34 B. CONFLICTS OF INTEREST OWNERSHIP .................................................................................................................. 35 C. STEPHENS PERSONAL TRADING ............................................................................................................................ 35 D. CONFLICT OF INTEREST WITH PERSONAL TRADING AND CLIENT TRADES .............................................................. 35 ITEM 12 BROKERAGE PRACTICES ...................................................................................................................... 36 A. BROKER-DEALERS SELECTION OR RECOMMENDATIONS ...................................................................................... 36 ITEM 13 REVIEW OF ACCOUNTS.......................................................................................................................... 37 ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION ..................................................................... 37 ITEM 15 CUSTODY .................................................................................................................................................... 38 ITEM 16 INVESTMENT DISCRETION ................................................................................................................... 38 ITEM 17 VOTING CLIENT SECURITIES............................................................................................................... 38 ITEM 18 FINANCIAL INFORMATION .......................................................................................................................................... 40 OTHER POTENTIAL CONFLICTS OF INTEREST ..................................................................................................................... 40 WHO TO CONTACT ......................................................................................................................................................................... 43 ADV Part 2A March 31, 2025 3  Item 4 Advisory Business A. Advisory Firm and Principal Owners Stephens Inc. (“Stephens”) is an Arkansas corporation, which registered with the Securities and Exchange Commission (“SEC”) as a broker-dealer in September 1946. Stephens registered as an investment advisor with the SEC on September 19, 1980 and began providing investment advisory services at that time. Who Are Our Owners Our Firm is owned by SI Holdings Inc. which is a privately held company owned by the Warren A. Stephens Trust which is controlled by Warren A. Stephens. Stephens is owned by the following individuals and entities in the percentages noted: 100%, Trustee of 100%, which owns 100%, which owns 100%, which owns Warren A. Stephens Warren A Stephens Revocable Trust #Two Stephens Financial Services LLC SI Holdings Inc. Stephens Inc. B. The Types of Investment Advisory Services We Provide We provide investment advisory services to individuals, pension plans, foundations, corporations, other business entities and other types of clients. Our investment focus is on US equity securities, fixed income securities, mutual funds, exchange-traded securities, American depository receipts of foreign companies, options, commodities and other types of securities that may be purchased for client accounts depending on the investment objective of the client. Stephens also provides advice to certain clients regarding private equity investments, precious metals, other pooled investment vehicles and other investments. C. Advisory Services Stephens’s investment advisory services seek to tailor an investment program for the financial goals and objectives of a particular client. When we are engaged as an investment advisor, the client typically pursues one or more of our investment strategies. Clients may impose investment restrictions on their accounts, such as restrictions on investing in particular securities or types of securities or restrictions on investing in particular industries. Except with respect to the payment of the fees or service charges or for correction of errors, Stephens is not authorized to withdraw or transfer any money, securities, or property out of a client’s account, without authorization from the client. Client acknowledges and understands that brokerage or securities transaction execution services provided by any person or entity other than Stephens or Pershing LLC (“Pershing”) are separate from and in addition to the wrap fee for the account. Additionally, regular service charges shall apply to client’s account for brokerage services other than securities execution services provided by Stephens. Stephens and its affiliates performs advisory and/or brokerage services including investment reporting for various clients, and Stephens gives advice or take actions for other clients that differ from the advice given or the timing or the nature of any action taken for your account. In addition, Stephens may, but is not obligated to, purchase or sell or recommend for purchase or sale any security, which Stephens or any of its affiliates may purchase or sell for their own accounts or the account of any other client. Stephens and Pershing will not charge commissions on securities transactions that are executed through Stephens or Pershing for these advisory accounts. Your account would be responsible to pay any commission charges imposed by any other brokerage firm on any securities transactions executed through any other brokerage firm, and such charges would be in addition to the wrap fee and any other applicable charges incurred by your account. By executing trades through Stephens with Pershing, your account might forego benefits, such as participation in block trades or negotiated transactions that might be available through other brokerage firms. ADV Part 2A March 31, 2025 4  On June 5, 2019, the SEC issued its interpretation of the Standard of Conduct for Investment Advisers and rescinded certain previously issued no action letters. As a result of these changes, Stephens will not seek to enforce any provision of an investment advisory agreement with a retail investor which discharges Stephens or its agents from liability to the retail investor client. For Employee Retirement Income Security Act (“ERISA”) and Individual Retirement Account (“IRA”) accounts, when Stephens provides non-discretionary investment advice to the client regarding such an account, we are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we are compensated can create conflicts of interest, so we have established procedures which require us to act in the client’s best interest and not put our interest ahead of the client’s. This is discussed further in Item 5.C. Stephens Insured Bank Sweep Program Stephens makes available to clients whose accounts are custodied at Pershing the opportunity to participate in the Stephens Insured Bank Sweep Program (“Bank Sweep Program”). In this program all of the uninvested cash in a client’s account is automatically deposited, or “swept” into FDIC insured, interest-bearing deposit accounts at one or more banks, which participate in the Bank Sweep Program. None of the banks participating in the Bank Sweep Program are owned by or affiliated with Stephens. For more information about the Bank Sweep Program please review these important disclosures at www.stephens.com/investment-disclosures/ which are incorporated by reference into this Form ADV Part 2A. Stephens offers the Bank Sweep Program as a service and is not obligated to offer this or any sweep product or to make available to a sweep product that offers a rate of return that is equal to or greater than other comparable products or investments. The interest rates paid on Deposit Accounts at a Bank may be higher or lower than the interest rates available to depositors making deposits directly with the Bank or other depository institutions in comparable accounts and for investments in other cash equivalent investments through Stephens. The Bank Sweep Program is not available to ERISA plans with accounts at Stephens such as employee benefit plans, retirement plans, defined contribution plans, defined benefit plans, (collectively, “ERISA accounts”) or to traditional and rollover IRA Accounts Roth, SEP, SIMPLE and inherited IRAs; Keogh plans; and Coverdell education savings accounts. The Bank Sweep Program for your account should not be viewed as a long-term investment option. If you desire, as part of an investment strategy or otherwise, to maintain a cash position in your account for other than a short period of time and/or are seeking the highest yields currently available in the market for your cash balances, please contact your Financial Consultant to discuss investment options that are available outside of the Bank Sweep Program to help maximize your return potential consistent with your investment objectives, liquidity needs and risk tolerance. Please note, however, that available cash accumulating in your account will not be automatically swept into any investment you purchase outside of the Bank Sweep Program. Nothing obligates you to participate in the Sweep Program. You may receive a higher rate of return through products offered outside the Sweep Program, including Money Market Funds offered through your account with Stephens and Pershing. Each Deposit Account constitutes a direct obligation of the Bank and is not directly or indirectly an obligation of Stephens or Pershing. Stephens and Pershing do not guarantee in any way the financial condition of the Banks or the accuracy of any publicly available financial information concerning such Banks. You are responsible for monitoring the total amount of deposits that you hold with any one Bank, directly or through an intermediary, in order for you to determine the amount of deposit insurance coverage available to you on your deposits. Stephens and Pershing are not responsible for any insured or uninsured portion of a Deposit Account. D .Wrap Fee Programs Our Separately Managed Account Advisory Programs ADV Part 2A March 31, 2025 5  We offer investment management on a discretionary basis in some programs and on a non-discretionary basis through separately managed accounts in the other programs. In addition to other indications of individual ownership, including the right to withdraw, hypothecate, vote, or pledge securities held in the wrap fee client’s account, a wrap fee advisory client has the ability to place limitations and/or restrictions on the investments in their portfolio. Where restrictions are imposed, Stephens will not knowingly make any discretionary investments of the client’s portfolio assets in violation of these restrictions, but the investment performance of the client’s account will likely differ (positively or negatively) from other clients following a similar investment strategy, that is not subject to the same restrictions. The minimum account size for wrap fee programs varies from program to program, and a person considering a wrap fee program should review the disclosure document provided by Stephens of the applicable program for details regarding the operation of the program, its risks, fees, and other charges. See Item 5 for further discussions on fees. In determining the suitability of an investment strategy for a particular wrap fee program client, we rely on the information provided by the client regarding the financial objectives of the client for each account. This information comes from, among other sources, personal interviews with the client and written questionnaires completed by the client and other communications with the client or its representative regarding the client’s situation, investment objectives, risk tolerances and investment restrictions, if any. Our strategies are not appropriate for all investors, and investors should only invest a portion of their portfolio in these programs. Discretionary Wrap Programs In the following types of separately managed accounts, we have the discretionary authority to determine the securities, and the amount of securities, to be bought and sold for our clients without obtaining specific client consent. The discretionary authority regarding investments may, however, be subject to certain restrictions and limitations placed by the client on transactions in certain types of securities or industries or to restrictions or limitations imposed by applicable regulations. Stephens seeks to fully invest cash balances at all times, investing assets otherwise un-invested in the Bank Sweep Program, or for ERISA and IRA accounts in money market mutual funds. Professional Wealth Management Professional Wealth Management (“PWM”) program is an investment advisory program offered by Stephens. Clients receive advice from seasoned professional managers, with individual attention to the client’s investment needs and objectives. Stephens or the Professional Wealth Management Financial Consultant (“PWM FC”) also provides brokerage and other services to certain clients or engages in other functions and duties associated with the Stephens’ business as advisor or as broker-dealer, to which they may devote as much time as necessary. In the PWM program, Stephens provides investment management services for client assets on a discretionary basis, utilizing strategies that include equity, fixed income, other investments, or a combination, in some cases, that include alternative investments. The goal of the PWM program is to pursue an investment program to address the client’s investment objectives subject to market conditions. In balancing the potential return for a client’s portfolio against the risk exposure in the portfolio, the PWM FCs consider the risk tolerances of the client, and discuss with the client their investment objectives. The client’s stated investment objectives and other information provided by the client, leads to an asset allocation strategy designed to seek to achieve returns based on and commensurate with the client’s risk tolerance and time horizon, without exposing the client’s portfolio to excessive risks. ****************************************** Stephens Allocation Strategies The Stephens Allocation Strategies (“SAS”) program is an asset allocation program sponsored and administered through Stephens whereby the client is offered a strategy of purchasing a portfolio of “no load” or “load waived” mutual funds and Exchange Traded Funds (“ETFs”) representing a broad spectrum of equities, fixed income, and alternative investment markets through Stephens. Mutual funds and ETFs are collectively referred to as “Funds” in this document. ADV Part 2A March 31, 2025 6  Fund’s Strategies Stephens, acting as the registered investment advisor manages the selection of Funds representing each asset class included in the SAS asset allocation models in the program and establishes standard SAS model asset allocation portfolios for differing risk and time horizon parameters. Ongoing investment monitoring, fund replacement, periodic rebalancing and investment performance measurement are provided by Stephens. Based on individual consultations with the client and their investment objectives, a SAS asset allocation model recommendation is selected by the FC for the client’s account, intended to reflect the investment objectives, risk tolerance and investment time horizon communicated to the FC by the client. Following the client’s approval of the recommended asset allocation, Stephens will initiate and Pershing will execute all transactions that are required to manage the client’s account in accordance with such asset allocation. Best execution is sought for all transactions. Stephens has investment discretion to change the Funds representing any asset class, to add or eliminate asset classes from the asset allocation model and to adjust the standard SAS asset allocation models, all consistent with the client’s investment objectives and other information as communicated to Stephens. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b-1 fees are received on client holdings, these will be rebated to the advisory client. Stephens Allocation Strategies In the SAS advisory program, we offer a range of models provided by Stephens with a range of mutual funds and ETFs that Stephens has selected and approved. Our SAS Investment Committee evaluates the Funds. Our SAS Investment Committee has developed a disciplined process for evaluating the Funds. Our research is focused on a review of both qualitative and quantitative factors, factors that are designed to deliver a wealth of detailed information about the Funds available through this advisory program. The replacement of Funds in a client portfolio may happen under the following circumstances: • Fund’s philosophy changes; • Fund exposes client’s account to investment style change; • Fund and/or firm undergoes ownership change or major personnel change; • Fund performance lags peer group benchmarks; • Fund holds an unnecessarily large cash position. ***************************************** Stephens Capital Management (“SCM”) Discretionary Program In the Stephens Capital Management Discretionary Program (“SCMD”), seasoned Investment Advisor Representatives (“IARs”) manage client assets on a discretionary basis, utilizing both equity and fixed income strategies and, in some cases, alternative investment classes. The goal of SCMD is to seek to earn a high total return on investments for the client consistent with the client’s investment objectives and investment strategies, subject to market conditions. From time to time investments include mutual funds or other pooled investment products. IARs are responsible for making day-to-day discretionary investment decisions subject to oversight and review by the SCM Supervisory Principals. ***************************************** ADV Part 2A March 31, 2025 7  Stephens Capital Management Fixed Income Strategy In the Stephens Capital Management Fixed Income Strategy (“SCM-FIS”), Stephens Capital Management (“SCM”) manages client assets on a discretionary basis using a fixed income strategy. The SCM-FIS is overseen by the Fixed Income Strategy Investment Committee (“Investment Committee”), which has overall responsibility for investment policy, strategy and advises on security selection parameters. SCM IARs make day-to-day investment decisions for accounts advised in the SCM-FIS program within the parameters set forth by the Investment Committee. The Investment Committee is composed of Larry Bowden, Troy Clark, David Moix, Abigail Buchanan, Larry Middleton, Bo Brister and Brian Baumeister and seeks to provide consistent performance by actively managing portfolios based on a top down macro investment strategy that adjusts duration and sector allocations on the investment committee’s market views in accordance with evolving economic data, developments and themes. The Investment Committee employs a strategy of disciplined management of portfolios constructed primarily of investment grade U.S. government, U.S. government agency and corporate bonds with the objective of maximizing risk-controlled returns over full market cycles. The goal of SCM-FIS is to seek to earn a high total return on income securities for the client consistent with the client’s investment objectives subject to market conditions. SCM-FIS seeks to fully invest cash balances into investment grade debt instruments. Clients choosing the SCM-FIS program will own a portfolio comprised of U.S treasury securities, government agency securities, mortgaged backed securities, structured products, municipal bonds and investment grade corporate bonds. Clients may elect to direct deviations from the parameters set forth herein in the management of their particular accounts in appropriate cases. The average maturity of the portfolios will be managed to take advantage of the Investment Committee’s outlook for interest rates. The style of management of the fixed income portfolios managed in SCM-FIS is duration management. ***************************************** Stephens Spectrum Program In the Stephens Spectrum Program (“SSP”), SCM manages client assets on a discretionary basis, utilizing primarily mutual funds and exchange traded funds representing a broad spectrum of equity and fixed income markets. In addition, SCM may invest in mutual funds that seek capital appreciation primarily through short positions in domestically traded equity securities and indices, mutual funds that invest in commodities, and mutual funds that employ a merger arbitrage strategy. All accounts are advised and managed by the Spectrum Investment Committee, which has overall responsibility for investment policy, strategy and security selection. The Spectrum Investment Committee is responsible for making day- to-day investment decisions. The goal of SSP is to seek to earn a high total return on investments for the client consistent with the client’s asset allocation boundaries. Prior to January 1, 2022, this program was known as the Asset Allocation and Advisory Services Program (AAA). ***************************************** Stephens Fixed Income Management Stephens Fixed Income Management (“SFIM”) is a division of Stephens. SFIM manages client assets on a discretionary basis, under the Stephens Fixed Income Management program. All accounts are advised and managed by the Fixed Income Management Committee. The goal of SFIM is to seek to earn a high return on income investments for the client consistent with the client’s investment objectives subject to market conditions. SFIM seeks to fully invest balances at ADV Part 2A March 31, 2025 8  all times. The portfolio objective will be to invest in fixed income securities and money market funds, which invest in fixed income securities. Limited-Discretionary Wrap Programs Stephens provides wrap fee programs in which client assets are managed by Stephens or designated third party investment managers (“Sub-Advisors”). Under these programs, the Sub-Advisor provides discretionary investment management services for the management of client assets. Each client enters into an investment Advisory Contract with Stephens. The Sub-Advisor in turn has a separate Sub-Advisory agreement with Pershing. The client pays an agreed fee monthly in advance to Stephens, based on the value of the assets under management that covers the advisory fees of both Stephens and the Sub-Advisor. Stephens seeks to fully invest cash balances at all times, investing assets otherwise un-invested in the Bank Sweep Program, or for ERISA or IRA accounts in money market mutual funds. ***************************************** Stephens Managed Assets Program The Stephens Managed Assets Program (“MAP”) is an asset allocation program sponsored by Stephens wherein Stephens manages the account or the client selects one or more Sub-Advisors to direct the investment of the client’s assets. In this program, Stephens acts as the registered investment advisor establishing a separate account for the client. A separate account is a portfolio of individual securities managed for the client utilizing strategies that include equity, fixed income, other investments or a combination. Where the client chooses to engage one or more Sub-Advisors, the FC will assist in selecting the particular Sub-Advisors to manage or assist Stephens in managing the client’s assets based upon the client’s investment objective as described below. The Strategy A strategy is customized for the client by using sub-accounts (“Sub-Accounts”) which follow a strategy of Stephens or various Sub-Advisors selected by the client. Stephens will recommend Sub-Advisors to the client from the list of Sub- Advisors, which are included in Stephens’ list of available Sub-Advisors for the MAP program. The client’s stated investment objectives and other information provided by the client, leads in most situations to an asset allocation strategy designed to seek to achieve returns based on and commensurate the client’s risk tolerance and time horizon, without exposing the client’s portfolio to excessive risks. Sub-Advisors not currently available through Stephens may be added, at Stephens’ sole discretion. In the MAP, certain Sub-Advisors provide Stephens with their recommended Model Portfolios, and Stephens can deviate from the recommended Models if it deems appropriate. In these instances Stephens has discretion over the client’s assets in the Sub-Account rather than the Sub-Advisor (“Model Sub-Advisor”). Where the Sub-Advisors selected by the client manage client’s assets directly rather than through a Model, the Sub-Advisor (“Non-Model Sub- Advisor”) has discretion over the client’s account. (Note: the term “Sub-Advisor” without further qualification or description includes both Model and Non-Model Sub-Advisors.) Each Sub-Advisor will be responsible for complying with all legal and regulatory requirements applicable to its activities as the manager of funds in Sub-Accounts they manage. If Stephens or Pershing removes a Sub-Advisor from the list of Sub-Advisors available through Pershing, Stephens will recommend that the client transfer management of any assets previously managed by the removed manager to a new Sub-Advisor or Sub-Advisors, selected by the client and included on the list of Sub-Advisors available through Stephens. Stephens will review the investment activities of the Sub-Advisors in management of assets and provide regular reports on the status and performance of the Sub-Advisors. Pershing will execute all transactions on Stephens’ behalf in the client’s account following the instructions of the client and/or the designated Sub-Advisor(s), unless the investment is below the minimum amount of shares allowed to trade. Information about the client is communicated to Stephens and to the Non-Model Sub-Advisers on the initial opening of the advisory account and from time to time, thereafter. A Stephens New Account Agreement (“Agreement”) and ADV Part 2A March 31, 2025 9  Advisory Contract must be completed by each client and maintained by Stephens. The Agreement contains account name and address, investment objective and specific financial information. Client information may be updated from time to time upon notification from the client of any material changes and noted within the client file. Stephens Managed Assets Program In the MAP advisory program, we offer a wide range of investment strategies provided by Stephens and Sub-Advisors that we have selected and approved. If Sub-Advisors have more than one strategy, we may include only some of those strategies in the program, and may assign different statuses to different strategies. Our MAP Investment Committee evaluates Sub-Advisors and strategies. Sub-Advisors and strategies may only participate in MAP if they are on the Stephens approved list. Our MAP Investment Committee has developed a disciplined process for evaluating investment managers. Our research is focused on a review of both qualitative and quantitative factors; factors that are designed to deliver a wealth of detailed information about the investment products available through this advisory program. The client will select investments or an investment strategy or strategies following discussion with their FC about their investment objectives, the recommended allocation and potential Sub-Advisors with which to implement proposed strategies. When the client approves a proposed strategy, the client’s account may be established and assets placed with the agreed Sub-Advisor(s) to operate the plan. The replacement of Sub-Advisors in a client portfolio may be recommended under the following circumstances: • Change of client’s investment situation or goals; • Sub-Advisor philosophy changes; • Sub-Advisor exposes client’s account to investment style change; • Sub-Advisor firm undergoes ownership change or major personnel change; • Sub-Advisor performance lags peer group benchmarks; • Stephens, in consultation with client, determines to effect a change; or • Sub-Advisor holds an unnecessarily large cash position. Sub-Advisor Fees Where Sub-Advisors are selected, we, on your behalf, pay a part of the fee we receive from you to the Sub-Advisor for services provided to you. The portion of the asset-based fee paid by Stephens depends upon the asset class and the investment style. Stephens generally pays the Sub-Advisors between .25% and .55%. ***************************************** Stephens Unified Managed Account The Stephens Unified Managed Account (“UMA”) program is a wrap fee program sponsored by Stephens that offers clients the ability to integrate investment products into a single advisory account. The program allows clients to construct a portfolio with allocations to various strategies (“Sleeves”) which consist of any of the following investment products (“Products”): (i) mutual funds; (ii) ETFs; and (iii) securities selected in model portfolios by one or more Sub- Advisors. Where the client chooses to engage one or more Sub-Advisors, the FC will assist in selecting the particular Sub-Advisors to manage or assist Stephens in managing the client’s assets based upon the client’s investment objective as described below. The Strategy The UMA program is based on asset allocation among various strategy Sleeves. Based upon the client’s stated investment objectives and other information provided by client, an asset allocation strategy is developed to seek to achieve returns based on and commensurate with the client’s risk tolerance and time horizon, without exposing the client’s portfolio to excessive risks. The FC, with approval from the client, can select any asset allocation as long as at least two strategy Sleeves are chosen. Stephens selects the Products that are available in the UMA program and determines which Sleeve will contain each product based upon its respective investment strategy. Products offered in the UMA program do not represent the full spectrum of products available through other programs offered by Stephens. ADV Part 2A March 31, 2025 10  Products available in the UMA program may be subject to certain investment minimums, as may be determined by Stephens and/or the relevant Sub-Advisor or Fund. Products not currently available in the UMA program may be added at Stephens’ sole discretion. In the UMA program, Stephens has investment discretion to change the Product selections within each asset allocation Sleeve. With the client’s written consent, Stephens will add or remove asset classes or otherwise adjust the asset allocation that was approved by the client as long as the assets remain in the UMA program. If Stephens removes a Product from the list of products available in the UMA program, Stephens will notify the FC of the change and provide 30 days’ notice to implement a change to another Product within that Sleeve or contact the client and discuss changes to the overall asset allocation. After the 30-day period, Stephens will select the replacement Product. Stephens will review the performance of the Products and the FC can provide regular reports on the status and performance of the Products to the client. Pershing will execute all transactions on Stephens’ behalf in client’s account following the instructions from the FC, the client or the designated Sub-Advisor(s), unless the investment is below the minimum amount of shares allowed to trade. Information about the client is communicated to Stephens and to a Non-Model fixed income Sub-Advisor on the initial opening of the advisory account and from time to time, thereafter. An Agreement and Advisory Contract must be completed by each client and maintained by Stephens. The Agreement contains account name and address, investment objective and specific financial information. Client information may be updated from time to time upon notification from the client of any material changes and noted within the client file. Generally, Sub-Advisors in the UMA program either provide Pershing with their model portfolio or direct their trading to Pershing for execution. In both of these situations, Pershing executes these trades at no additional charge to the clients because execution charges are included in the wrap fee the client pays Stephens. However, to achieve best execution and for other reasons, Non-Model Sub-Advisors have the ability to trade away from Pershing. When Non- Model Sub-Advisors trade away from Pershing, clients will incur additional costs for fixed income securities. The additional fees are per bond or on a per transaction basis which are embedded in the net price you receive. The number of Non-Model Sub-Advisors in the UMA program that direct trades to other broker-dealers can change as Non-Model Sub-Advisors are added or removed from the program. Account Rebalancing Stephens will review UMA program accounts annually for drift based on their initial allocations to the various strategy Sleeves. Accounts with absolute variances of 3% or more from their Sleeve allocations will be rebalanced. In taxable accounts, rebalancing may cause a taxable event, and you should consult your tax advisor. Stephens Unified Managed Account Program In the UMA program, we offer a wide range of investment strategies provided by Stephens, Sub-Advisors, and Funds that we have selected and approved. If Sub-Advisors or Funds have more than one strategy, we may include only some of those strategies in the program, and may assign different statuses to different strategies. Our UMA Investment Committee evaluates Sub-Advisors and their strategies and Funds. Sub-Advisors and strategies and Funds may only participate in UMA if they are on the Stephens approved list. Our UMA Investment Committee has developed a disciplined process for evaluating investment managers. Our research is focused on a review of both qualitative and quantitative factors; factors that are designed to deliver a wealth of detailed information about the investment products available through this advisory program. The client will select investments or an investment strategy or strategies following discussion with their FC about their investment objectives, the recommended allocation and potential Sub-Advisors and/or Funds with which to implement proposed strategies. When the client approves a proposed strategy, the client’s account may be established and assets placed with the agreed Sub-Advisor(s) and Funds. Sub-Advisors and Funds in a client portfolio are considered for replacement under some the following circumstances: ADV Part 2A March 31, 2025 11  • Change of client’s investment situation or goals; • Sub-Advisor or Fund philosophy changes; • Sub-Advisor or Fund exposes client’s account to investment style change; • Sub-Advisor firm or Fund undergoes ownership change or major personnel change; • Sub-Advisor or Fund performance lags peer group benchmarks; • The FC or client determines to effect a change; or • Sub-Advisor or Fund holds an unnecessarily large cash position. Sub-Advisor Fees Where Sub-Advisors are selected, Stephens, on your behalf, pays a part of the fee received from you to the Sub-Advisor for services provided to you. The portion of the asset-based fee paid by Stephens depends upon the asset class investment style. Stephens generally pays the Sub-Advisors between .25% and .55%. ***************************************** Stephens Small-Mid Cap Core Growth Program Stephens Small-Mid Cap Core Growth (SMID) program is an investment advisory wrap program of Stephens. The investment portfolio of SMID accounts is managed by Stephens Investment Management Group, LLC (SIMG), an affiliate of Stephens. SIMG was organized in July 2005 and is registered with the SEC as an investment advisor. SIMG manages and directs the investment of the assets in each SMID client’s account on a discretionary basis in accordance with its small and mid-cap equity investment style and on the basis of the individual objectives and needs of the client within the criteria established by the SMID. SIMG personnel also provide services to other clients and to other products or programs. In the SMID program, SIMG establishes the investment policy and strategy for the portfolio, selects the securities to be included in the portfolio and makes the day-to-day investment decisions. The goal of SIMG is to seek growth of the equity value of a portfolio of small and mid-cap equity investments for clients, consistent with clients’ investment objectives. SIMG attempts to identify core growth stocks among stocks of companies that have a market capitalization at the time of purchase no larger than the market capitalization of the largest company then included in the Russell 2500TM Growth Index, using a disciplined bottom-up approach, employing financial screening techniques, fundamental research and the portfolio managers’ judgment, with a focus on identifying small-cap companies and mid-cap companies believed to have above-average potential for equity growth. The Russell 2500TM Index is a trademark/service mark of the Frank Russell Company. Russell® is a trademark of the Frank Russell Company. The portfolio benchmark is the Russell 2500TM Growth Index. The Russell 2500™ Growth Index measures the performance of those Russell 2500™ companies with higher price-to-book ratios and higher forecasted growth values. SIMG seeks, as a rule, to fully invest cash balances. SIMG invests SMID assets primarily in long positions in equity securities. However, from time to time SIMG invests SMID assets in other types of securities, including without limitation, short term fixed income securities, exchange- traded funds and other investment company securities, and stock index futures. SIMG generally seeks to fully invest cash balances. Investments made through the SMID program are concentrated in investments in equities of small- and mid- cap growth companies and are not diversified across other asset classes. Small and mid-cap growth strategies may be more volatile and less liquid than other investment strategies. Investing in small-cap and mid-cap issuers involves greater risk than investing in more established companies and investors should only invest a portion of their total portfolio in these securities. Typically, individual investors are advised not to allocate more than ten to fifteen percent of their overall investment portfolio to a small and mid-cap growth strategy. The SMID portfolio is not managed for tax efficiency. ADV Part 2A March 31, 2025 12  The investment strategy used by SIMG in the SMID program is also available to appropriate Stephens clients in the Stephens MAP. ***************************************** Non-Discretionary Wrap Programs Stephens Advisor In the Stephens Advisor (“SA”) program, clients receive advice from the FC with individual attention to the client’s investment needs and objectives. FCs provide advice to clients utilizing strategies that include equity, fixed income, balanced, other investments, or a combination, in some cases that include alternative investments. FCs provide advice and make recommendations to clients at client’s request or as the FC deems appropriate. FCs in the SA program do not have discretionary authority over client assets, and all transactions in client assets are directed by the client or the client’s designee. Investment Services Stephens shall periodically provide clients with investment advice, which can include recommendations regarding investing in available assets in a manner consistent with the client’s investment objectives; and pursuant to your consent, which shall be obtained prior to each transaction, in order to accept transaction in the SA account. Stephens will not provide advice with respect to positions classified as unsupervised assets in the account. As part of the range of services available to clients in the SA program, advisory variable and fixed annuity contracts may be offered to appropriate retirement investors who are seeking certain income and death benefit solutions afforded by these products. ***************************************** Stephens Capital Management Non-Discretionary Program In the Stephens Capital Management Non-Discretionary Program (“SND”), IARs advise clients regarding their management of client assets on a non-discretionary basis, utilizing both equity and fixed income strategies and, in some cases, alternative investment classes. The goal of SND is to assist clients with the management of their investment assets consistent with the client’s investment objectives and investment strategies, subject to market conditions. From time to time investments include mutual funds. IARs are responsible for providing non-discretionary investment advice, subject to oversight and review by the SCM Supervisory Principals. The client may pursue its own investment objectives. ***************************************** StephensChoice Program The StephensChoice Program (“SC”) is a platform designed by Stephens to assist qualified retirement plans or other deferred compensation programs (“Plan”) with establishing an appropriate asset allocation for the investment of plan assets through investment in a portfolio of “no load” or “load waived” mutual funds through Stephens based upon a line- up of mutual funds representing a range of designated asset classes. Mutual Fund Strategy The SC standard line-up is comprised of one or more actively managed mutual funds representing each asset class included in the SC program. Stephens establishes and communicates to the Plan Sponsor and/or Trustee such ADV Part 2A March 31, 2025 13  investment line-up and, if chosen by the Plan Sponsor and/or Trustee, a choice of five model asset allocation portfolios (each, an “SC Model”) for differing risk profiles. In some cases, participants may be able to select a custom glide path product that automatically adjusts the mix of funds to become less risky over time based on the participant’s time horizon parameters. Stephens provides ongoing investment selection, monitoring, fund replacement, investment performance measurement and quarterly reporting throughout the life of the account. In addition, periodic rebalancing is provided in certain accounts which are introduced to our clearing broker-dealer Pershing and custodied at Pershing. Stephens provides the services described above to clients under a Plan Services Agreement. For Plan Sponsor/Trustee Directed Accounts Based on individual consultations with the Plan Sponsor and/or Trustee and the risk tolerance questionnaire, one of five SC Models will be chosen from the SC funds line-up for each trustee directed account or for segregated participant accounts. The selected SC Model is intended to reflect the investment objectives, risk tolerance and investment time horizon communicated to Stephens by the Plan Sponsor and/or Trustee. Following the selection of SC Model, Stephens will initiate and execute the transactions that are required to invest the account in accordance with such SC Model’s asset allocation. Best execution is sought for all transactions. Participant Directed Accounts For Plans with participant directed accounts, the Plan Sponsor and/or Trustee makes the determination to use the SC line-up of funds, which Plan participants may elect to use in their individual accounts. If requested, Stephens will conduct group education and enrollment meetings to educate participants on the investment options in the Plan. Following initial enrollment, Stephens is available to communicate with individual Plan participants on an as needed basis, for educational purposes about their Plan account. SC Strategy Changes Stephens may periodically change the mutual funds representing any asset class in the standard SC line-up of funds, or add or eliminate asset classes from the standard SC platform line-up. Stephens communicates such changes in the standard line-up to Plan Sponsor and/or Trustee. The Plan Sponsor and/or Trustee has discretion to adopt or decline such changes, unless they have chosen to be a 3(38) fiduciary. Stephens with the Plan Sponsor and/or Trustee’s consent may realign the standard SC asset allocation models and/or change the mutual fund selections. Fees Fees for the SC program will be billed to the Plan Sponsor and/or Trustee or deducted from client’s Plan Participant’s account assets. Stephens collects fees from the client’s account(s) quarterly in arrears. In accounts for which Pershing acts as custodian, rates are set forth in the Plan Service Agreement, based on the daily average asset value of the assets in the account(s) for that calendar quarter. If the client uses a custodian other than Pershing, Stephens’ fee will be collected by the outside custodian and may be based on a different quarterly accounting method. SC is a wrap fee program in which the client pays a single fee for investment advisory services and related services, which unless otherwise provided will include executions, custody and clearing charges. Fees for other services, such as administrative or transfer fees will be charged at Stephens’ standard rates in addition to the wrap fee. Additionally, fees charged by the mutual funds included in each client’s portfolio will be borne by the Plan or Plan participant. Mutual funds typically charge an expense ratio to pay for portfolio management, administration, marketing, distribution, and other expenses. Additionally, many mutual fund companies impose (among other fees) short-term trading fees with respect to any purchase and redemptions of fund shares effected within a time frame designated by the mutual fund company (such as, but not limited to sixty (60) or ninety (90) days). Mutual fund companies may also impose other fees from time to time. Any fees imposed by any mutual fund company with respect to SC account assets will be charged to the account, whether resulting from fund transfers, withdrawals, rebalancing transactions, or other transactions in the account. Accounts that elect to use third-party custodians or third-party brokerage services will bear the costs of such third-party services in addition to the fees payable to Stephens. ********************************************* Stephens Spectrum 401(k) ADV Part 2A March 31, 2025 14  The Stephens Spectrum 401(k) (“SSK”) is a platform designed by Stephens to assist clients’ qualified retirement plans or other deferred compensation programs (“Plan”) to establish an appropriate list of investment options for asset allocation of the investment of plan assets. SSK offers clients the opportunity to invest in a line-up of index funds, (either ETFs and/or index mutual funds) (collectively, “Funds”) and/or Stephens designed asset allocation portfolios, that primarily utilize Funds. Stephens selects a line-up of Funds representing each asset class included in SSK and establishes and communicates to clients the lineup of Funds and standard SSK asset allocation portfolios for differing risk and time horizon parameters. Ongoing investment selection, monitoring, fund replacement, periodic reallocation, investment performance measurement and quarterly reporting are provided by Stephens, throughout the life of the account. SSK seeks to fully invest cash balances at all times, in the Stephens designed asset allocation portfolios. Stephens provides investment oversite as a non-discretionary fiduciary to the plan as defined by Section 3(21)(a)(ii) of ERISA. Alternatively, upon the mutual agreement of Stephens and the client, Stephens is able to provide investment oversite as the discretionary fiduciary as defined by Section 3(38) of ERISA. Stephens provides the services described above to clients under a Plan Services Agreement, and Stephens through Pershing also provides, if requested by the Trustee of the Plan, brokerage and/or custodial services needed to effect transactions for SSK accounts and certain compliance functions relating to the services provided by Stephens. If requested by the Trustee, Stephens will conduct group enrollment meetings on dates agreed to by the Trustee and Stephens. Stephens will be available to meet with Plan participants in connection with initial enrollment to assist participants in identifying the participant’s investment objectives, risk tolerance, and time horizon. Following initial enrollment, Stephens will be available to meet with individual participants on an as needed basis for advice and/or education . ***************************************** Pension Management Trust Program The Pension Management Trust Program (“PMT”) is an asset allocation program, made available to Arkansas Local Pension and Relief Plans (“the Plan(s)”) that were formerly participants in the Arkansas Local Government Pension Management Trust, pursuant to a trust agreement. Under the advice of SCM, as investment advisor, the local board selects certain participating investment management companies (the “Active or Passive Managers”) to direct their investments of funds. Assets include, but are not limited to, securities, mutual funds, money market funds, collective funds, exchange-traded funds, select individual fixed income securities and other investments. SCM provides advisory services to the Plans, by establishing asset performance comparisons, risk profiles, assisting participants in developing and writing investment policies, preparing asset allocation modeling, and ongoing monitoring of plan portfolios. The selected Active or Passive Managers manage their respective portions of the plan’s assets on a discretionary basis, utilizing Index/Active portfolio management. All accounts are advised and monitored by an IAR of SCM. The participating Active or Passive Managers, which are selected by the pension plans, make the day-to-day investment decisions and security selections in the program. From time to time investments in any of the strategies include mutual funds or separate accounts money management. ***************************************** Health Management Trust Program The Health Management Trust Program (“HMT”) is an asset allocation program, made available to Arkansas municipalities that become participants in the Arkansas Local Government Health Management Trust (“Participant(s)”), pursuant to a trust agreement. Under the advice of SCM, as investment advisor, the local board selects certain participating investment management companies (the “Active and/or Passive Managers”) to direct their investments of funds. Assets include, but are not limited to, securities, mutual funds, money market funds, collective funds, exchange- traded funds, select individual fixed income securities and other investments. SCM provides advisory services to HMT and to participating accounts, by establishing asset performance comparisons, risk profiles, assisting participants in ADV Part 2A March 31, 2025 15  developing and writing investment policies, preparing asset allocation modeling, and ongoing monitoring of Participant portfolios. The selected Active or Passive Managers manage their respective portions of the Participant’s Plan assets on a discretionary basis. All accounts are advised and monitored by an IAR of SCM. The managers of the funds or other investment portfolios in which the Participant’s Plan assets are invested make the day-to-day investment decisions and security selections in their respective funds or portfolios. The goal of HMT is to bring together investment managers creating a customized investment strategy subject to market conditions consistent with each Participant’s Plan’s risk profile and investment objectives, as approved by the Participant. From time to time investments in any of the strategies include mutual funds or separate accounts money management. ***************************************** Stephens Capital Management Advisory Services for Employee Benefit Plans The SCM division of Stephens also provides advisory services to employee benefit plan fiduciaries whereby, pursuant to an agreement with plan fiduciaries, SCM assists fiduciaries in choosing primary fund advisers or managers to invest plan funds and in certain cases advises the fiduciaries with respect to allocation of plan assets among funds managed by others. After the initial selection process of the primary advisor, SCM may provide the client with reports analyzing the primary advisor’s performance and comparing such performance with that of other indices with similar investment objectives. In certain cases, the plan compensates SCM for this service based upon a negotiated fee calculated as a percentage of assets under management or a set fee negotiated by the client. In other cases, the primary adviser compensates SCM on a percentage basis. Written agreements between SCM and plan fiduciaries are typically for one- year terms, subject to renewal. ***************************************** Stephens IA Consultations From time to time Stephens is asked to furnish clients with investment advice through arrangements which involve consultations and recommendations but do not involve trading of securities. In these consulting arrangements a separate investment advisory agreement is entered into specifying the scope of the services which will be provided and the fee to be charged. Consulting services may be provided with a fixed fee, an annual fixed fee paid quarterly or an annual fee paid quarterly based on a percentage of the assets subject to the consulting agreement. Fees are negotiated in advance and are payable as negotiated and agreed to by the client and Stephens. Either party may terminate consulting contracts upon written notice. In the course of providing these services, Stephens may develop and present periodic reports regarding the client’s investments. The client and Stephens jointly review many of the client’s applicable financial considerations including, but not limited to time horizon, liquidity needs, risk tolerance, net worth, cash flows, education goals, retirement goals, wealth transfer goals and life & long term care insurance needs. Stephens provides the client with personalized financial planning and investment recommendations based upon the information provided by the client and the results of the financial plan. The client is under no obligation to act upon the recommendations of Stephens. If the client does elect to act on any of the recommendations, the client is under no obligation to effect the transactions through Stephens. ***************************************** Financial Planning Services Stephens offers comprehensive financial planning services to its clients in order to assist clients in identifying and striving to achieve long-term financial goals for themselves and their families. These services can include personalized financial planning and investment recommendations, and assistance with other financial matters, including trusts and estates and taxation issues. ADV Part 2A March 31, 2025 16  Stephens provides the client with these services based upon the information provided by the client and the results of the financial plan. The client is under no obligation to act upon the recommendations of Stephens. If the client does elect to act on any of the recommendations, the client is under no obligation to effect the transactions through Stephens. ***************************************************** Retirement Advisory Platforms – Non Discretionary Stephens Retirement Solutions In the Stephens Retirement Solutions (“RSP”) program, clients receive advice from their FC with individual attention to the client’s retirement investment needs and objectives. FCs provide advice to clients utilizing equity, fixed income, balanced, other investments, or a combination. This program is designed for clients with limited trading requirements. FCs in the RSP program do not have discretionary authority over client retirement assets, and all transactions in client assets are directed by the client or by the client’s designee. Investment Services Stephens shall periodically provide you with investment advice which can include recommendations regarding investing in available assets in a manner consistent with your investment objectives; and pursuant to your consent, which shall be obtained prior to each transaction, in order to accept transaction in the RSP account. Stephens will not provide you with advice with respect to positions classified as unsupervised assets in the account. ***************************************** Stephens Retirement Access The Stephens Retirement Access (“SRA”) program is now closed to new investors. In the Stephens Retirement Access (“SRA”) program, clients receive advice from the FC with individual attention to the client’s retirement investment needs and objectives. FCs provide advice to clients utilizing strategies that include equity, fixed income, balanced, other investments, or a combination. The program is designed for clients with minimal trading requirements. FCs in the SRA program do not have discretionary authority over client retirement assets, and all transactions in client assets are directed by client or client’s designee. Investment Services Stephens shall periodically provide you with investment advice which can include recommendations regarding investing in available assets in a manner consistent with your investment objectives; and pursuant to your consent, which shall be obtained prior to each transaction, in order to accept transaction in the SRA account. Stephens will not provide you with advice with respect to positions classified as unsupervised assets in the account. ***************************************** Research Advisory Services Equity Research Services In the Stephens Equity Research Services Program we offer research reports and other products and services (“Research Services”) provided by Stephens’ Research Department to a wide variety of Stephens clients. Under certain circumstances, we provide these Research Services for a fee to certain institutions upon their request. We do not offer Research Services for a fee to clients who are individuals. Research Services includes but is not limited to any and all of the following types of research products and services: ADV Part 2A March 31, 2025 17  • Research reports produced by research analysts; • Other research-related communications from research analysts relating to published research reports produced by research analysts; and • Access to research analysts in connection with research conferences, calls with clients and client meetings. Our Research Analysts cover in excess of 400 stocks focusing on more than 30 sub-sectors within five broad industries: Industrials and Energy • Consumer • Financial Services • Healthcare • • Technology, Media and Telecommunications Beyond essential company research and analysis, we strive to outperform our peers in client services, channel checking and management access. This can take the form of a field trip on a private jet or talking directly to an industry’s client base to acquire unique insights. We are committed to introducing our best investor clients to the best companies, and be the first to present non-consensus opinion. The core of our investment philosophy draws upon our heritage as an investor as well as an intermediary, backed by strong ethical standards. As an independent, privately-owned financial services firm, we are able to take an intermediate- to long-term approach to growth, allowing us to offer advice based solely on the best interests of our clients. Research Services do not include any services or communications provided by Institutional equity sales personnel. The delivery of Research Services does not include trade execution, trading or brokerage services provided to clients. Our advisory relationship with our clients is strictly limited to the provision of Research Services, and any trades, transactions or orders that may be executed, routed, or otherwise processed through us on behalf of clients will be handled by us solely in our capacity as a broker-dealer. E. Assets Under Management As of December 31, 2024, we managed the following amount of client assets as follows: $ 11,841,493,552 $ 3,771,290,459 $ 8,842,249,582 $ 24,455,033,593 Discretionary Non-Discretionary Consulting Total Assets Under Advisement Item 5 Fees and Compensation A. Overview of Fee Arrangements Stephens typically charges fees for investment advisory services based on a percentage of assets under management (“asset based fee”). Fees are negotiable and vary from client to client. Fees are generally charged quarterly in advance; in some cases fees are charged quarterly in arrears and may be paid on a schedule negotiated by the parties. In specialized situations, Stephens charges a fixed fee on a “per job” basis for certain services. These fees will be negotiated in advance by the parties. At any time the client can terminate its contract upon the terms without penalty. Please refer to Item 5 D. Services similar or comparable to those provided to a wrap program client may be available to the client at a higher or lower aggregate cost elsewhere on an unbundled basis. We encourage you to carefully consider other investment structures and programs which are available in considering whether to establish or maintain an advisory fee-based account. As a general matter, a fee-based advisory account approach may be considered appropriate for clients who rely on investment advice or investment management services or who engage in moderate to high levels of trading ADV Part 2A March 31, 2025 18  activity. A fee-based approach may be more economical for clients who engage in active trading, since the price per trade is reduced as the number of trades increases under a fee-based approach. However, fee-based advisory account arrangements may not be appropriate for clients who rely primarily on their own independent resources and judgments for making their investment selections and decisions and do not wish to purchase advisory services. Excluding the SRA, RSP and SND clients who engage in a lower level of trading activity might prefer a traditional brokerage account with a commission payable on each transaction, particularly if the client typically does not utilize advisory services for trading decisions, as transaction cost savings might be realized in the context of a traditional pay-per-trade commission structure. However, retirement accounts are not available through Stephens as brokerage accounts. Typically, a portion of any revenue that the firm realizes in connection with an advisory account will be included in the calculation of the compensation to be paid by the firm to the IAR or FC; and, therefore, the IAR or FC will experience conflicts of interest similar to those experienced by the firm. Performance Fees In addition to asset based fees, in certain situations, clients can enter into performance fee arrangements with Stephens. These fee arrangements compensate Stephens based on the performance of the client’s account. Clients entering into this type of fee arrangement must be qualified clients as defined in Advisers Act Rule 205-3. The terms of the performance fee are set forth in each client’s investment management agreement. Performance fee arrangements are approved on a case by case basis by Stephens. As specified in each client’s Investment Advisory Agreement, the amount of the Stephens Advisory Fee client pays is not considered in the computation of the performance fee. B. Payment of Fees Our advisory fees for investment advisory accounts are paid quarterly or monthly. Typically, Stephens will deduct the fee from the account being charged. In some cases the client will pay the fee out of its separate assets. Collection of Fees Stephens is authorized to deduct from your account depending on which advisory platform, each quarter or month in advance or arrears the amount of the total quarterly wrap fee as described in the Investment Advisory Agreement, and the other fees, if any, applicable to your account for such calendar quarter. Stephens will issue quarterly reports to you reflecting the transactions in your account and the performance of the investments. Service fees and other transactions changes, if any, will be applied to the account as incurred. C. Other Types of Fees and Expenses Clients May Pay The wrap fee covers custody services and securities execution services provided by Stephens or our clearing firm, Pershing, for the account. If a client’s account is under a wrap fee program such as the programs listed in Item 4.D, commission charges are also included as part of the Stephens advisory fee. This is more fully described in the brochure of each wrap fee program. Clients may engage an independent custodian. The fees of any custodian other than Pershing are not covered by the wrap fee and are the separate responsibility of the client. Clients may direct trading through another broker or other execution venue, and, in such a situation, the client will be responsible for all costs and commissions incurred in connection with such trading. Stephens Insured Bank Sweep Program The Stephens Insured Bank Sweep Program (“Bank Sweep Program”) is available to Stephens’ clients through our fully disclosed clearing broker-dealer, Pershing, and Pershing has appointed IntraFi Network, LLC (“IntraFi”) to provide certain services in connection with the Bank Sweep Program. In the Bank Sweep Program, each bank participating in the program pays a return based on the amount of funds in your Deposit Account at the bank. The interest rate applicable to your Deposit Accounts is determined by the amount of interest participating banks are willing to pay on the aggregate balance of the deposits minus: (i) the fees paid to Intrafi Network, LLC, as administrator, (ii) the fees paid to Pershing for its services, and (iii) the fees paid to Stephens. Stephens retains and exercises the right to negotiate its own fee and may reduce or increase its fee. Because an increase in fees to Stephens reduces the effective amount of the interest rate that is ultimately paid to customers, Stephens has a conflict of interest with regard to the Bank Sweep Program. Stephens’ compensation, exclusive of the fees paid to Pershing and IntraFi, for the Bank Sweep Program as applied to all clients will not exceed 6% ADV Part 2A March 31, 2025 19  per annum on the aggregate balances in the Deposit Accounts at the program banks. The total amount of the fee Stephens charges affects the amount of interest payable to clients on their Deposit Accounts since the higher Stephens’ fee is, the lower the amount of interest that is paid to Stephens’ clients. Stephens charges investment advisory fees as a percentage of client assets under management which includes cash assets in the Bank Sweep Program. This means that clients will pay Stephens’ investment advisory fee in addition to the fees charged in the Bank Sweep Program which are described above. More information on the current rates of return and fees is available at www.stephens.com/investment-disclosures/ which is incorporated herein. The interest rates on the Deposit Accounts will vary based upon the aggregate balance of all your “linked” Stephens accounts registered with the same tax ID number. This is referred to as your “Household Balance” and is described in more detail at www.stephens.com/investment-disclosures/. The rates and the Interest Rate Tiers may change from time to time. Further information on the Bank Sweep Program is available at https://www.stephens.com/investment- disclosures/stephens-insured-bank-sweep-program-rates/. These disclosures are incorporated herein. The interest rates paid on the Deposit Accounts at a Bank may be higher or lower than the interest rates available to depositors making deposits directly with the Bank or other depository institutions in comparable accounts and for investments in the money market mutual funds and other cash equivalent investments available through Stephens. You should compare the terms, interest rates, required minimum amounts, and other features of the Bank Sweep Program with other accounts and alternative investments. In deciding whether to participate in the Bank Sweep Program, clients should consider the return they are expected to receive versus the safety of the program. Banks participating in the Bank Sweep Program are not selected by Stephens, and each bank participating in the Bank Sweep Program is covered by FDIC deposit insurance up to the applicable FDIC limit. Banks in the program are expected to have acceptable credit but may not have “top tier” credit, and clients should evaluate credit quality and FDIC insurance coverage together with the return they are expected to receive. Funds in Advisory Programs Investing in Funds is more expensive than other investment options offered in your advisory account. In addition to our investment advisory fee, you pay the fees and expenses charged by the 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 of the Fund’s share price. These fees and expenses are an additional cost to you and are not included in the fee amount in your account statement. Each Mutual Fund and ETF expense ratio (the total amount of fees and expenses charged by the Fund) is disclosed in the prospectus. You do not pay a sales charge for purchases of mutual funds in your advisory account. However, some mutual funds charge, and do not waive, a redemption fee on certain transaction activity in accordance with its prospectus. In many instances, Client account assets are invested in money market funds, mutual funds, other investment companies, privately offered investment funds and other collective vehicles (collectively, “Funds”), and these investments have their own fees and expenses which are borne directly or indirectly by their shareholders. Where Stephens or its affiliates act as investment advisor, sponsor, administrator, distributor, selling agent, or in other capacities to such Funds, these Funds are deemed to be “Affiliated Funds.” Stephens or a Stephens affiliate receives the fees paid pro rata by all shareholders or partners of Affiliated Funds as described in the Fund’s prospectus. Client account assets can also be invested in Funds which are unaffiliated with Stephens or a Stephens’ affiliate (“Unaffiliated Funds”). For both Affiliated Funds and Unaffiliated Funds in which Stephens’ client assets are invested, Stephens receives distribution and shareholder servicing fees (“12b-1 fees”) from Funds on an ongoing basis as compensation for the administrative, distribution and shareholder services provided by Stephens. These services include such things as record maintenance, shareholder communications, transactional services, client tax information, reports filings and similar such services. These fees are paid under a plan adopted by the Funds pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended. If Stephens receives 12b-1 fees from a Fund with respect to a client’s mutual fund investment in the client’s advisory account and the client is paying Stephens an advisory fee on ADV Part 2A March 31, 2025 20  such investment, the 12b-1 fees will be rebated to the client’s advisory account. However, in client brokerage accounts which have mutual fund holdings, Stephens does retain the 12b-1 fees and shareholder servicing fees paid by the funds on these mutual fund holdings. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b-1 fees are received on client advisory holdings, these will be rebated to the advisory client. Effective November 15, 2019, Stephens has entered into a fully disclosed clearing arrangement with Pershing wherein Pershing provides certain recordkeeping and operational services to Stephens and to Stephens’ clients. The services provided by Pershing will include execution and settlement of securities transactions, custody of Stephens’ client accounts and extensions of credit for any margin transactions. Mutual funds are available to investors in a variety of different share classes all of which carry different expense ratios. Fund share classes that pay higher compensation carry higher expense ratios than share classes of the same mutual fund with lower expense ratios. Investing in a mutual fund share class with a higher expense ratio will negatively impact an investor’s return. Consistent with our fiduciary duty to clients, Stephens will take reasonable steps to ensure advisory clients are invested in share classes of mutual funds with the most appropriate expense ratio for their advisory account. Not all share classes are available to advisory clients of Stephens, and it is possible that cheaper share classes of a fund may be available directly with the fund, not available on the Pershing platform or away from Stephens. Additionally, because of the large number of mutual funds which are offered in an ever changing variety of different share classes, it is possible that investors may not receive cheaper share classes which come available after their initial investment in a fund. Unit Investment Trust (“UIT”) Sales Charge There are characteristically two components of the UIT sales charge: the transactional sales fee and the creation and development ("C&D") fee. The transactional sales fee does not apply to advisory accounts. The C&D fee is paid to the sponsor of the trust for creating and developing the trust, which includes determining the trust objective, policies, composition and size, selecting service providers and information services as well as providing other similar administrative and ministerial functions. Your trust pays the creation and development fee as a fixed dollar amount at the close of the initial offering period. The sponsor does not use the fee to pay distribution expenses or as compensation for sales efforts. Additional Fees In an advisory program, you will pay Stephens an asset-based fee for investment advisory and other services provided by Stephens or Pershing. These services include custody of securities and trade executions through Pershing on behalf of Stephens. The program fees do not cover:       the costs of investment management fees and other expenses charged by Funds and UITs; “mark-ups”, “mark-downs”, and dealer spreads that Stephens receives when acting as principal in certain transactions where permitted by law; brokerage commissions or other charges resulting in transactions not effected through Stephens with Pershing; account transfer fees; processing fees; or certain other costs or changes that may be imposed by third parties. As your Introducing Broker Dealer, Stephens can receive or pay compensation for directing order flow in equity securities. Pershing receives compensation for the direction of order flow in certain equity securities and listed options the source and nature of the compensation, if any, received in connection with trades will be furnished upon your written request to your FC or IAR. ADV Part 2A March 31, 2025 21  Custodial Services Pershing normally provides custodial services to Stephens’ clients. Custodial services provided by Pershing include custody of securities in your account, periodic statements, certain tax reporting and other similar services. Your account will be subject to the terms and conditions described in the Investment Advisory Agreement/Contract, Agreement and any separate agreement or agreements executed in connection with the account. Stephens includes custodial fees for custody services and securities services provided by Pershing within the wrap fee charge. If a client’s account is under a wrap fee program, commission charges are included as part of the Stephens advisory fee unless the client has selected a third party advisor who “trades away” from Pershing. Clients may engage an independent custodian. The fees of any custodian other than Pershing are not covered by the wrap fee and are the separate responsibility of the client. Clients may direct trading through another broker or other execution venue, and, in such a situation, the client will be responsible for all costs and commissions incurred in connection with such trading. Pershing Relationship Pershing is the clearing firm for our securities business. Due to this business relationship, Pershing shares with us a portion of the transaction costs and fees you pay to Pershing for certain transactions and services. The compensation we receive is an additional source of revenue to Stephens, and it defrays our costs associated with maintaining and servicing client accounts. Your advisory fee is not reduced or offset as a result of any revenue that Pershing shares with Stephens. The following is a brief description of some of the revenue and other items. • • • • • • Pershing pays us on a quarterly basis an Active Account Credit in support of our ongoing investment in various businesses, marketing and technology initiatives relating to the services we offer. This Active Account Credit is based on the total number of Stephens client accounts held on the Pershing platform. Pershing also pays us a Basis Point Credit each quarter which is computed based on the total value of Stephens client accounts held on the Pershing platform. Pershing also provides consulting and other assistance to us from time to time. Stephens receives revenues from Pershing on any investor free credit balances. These revenues are not received by Stephens for free credit balances in ERISA or IRA accounts. Stephens determines the margin debit interest rate and receives any amounts paid by clients in excess of the Fed Funds Target Rate plus 85 basis points. Stephens determines the interest rate charged to clients who obtain non purpose loans within parameters set by Pershing. Stephens receives 100 bps of the interest paid on the loan from Pershing except in situations where Stephens has agreed to receive a lesser amount. Pershing pays us a placement fee for each CD purchased through Pershing by a Stephens’ client. Pershing pays us a portion of the revenues it receives for banking services provided to clients. • • For the period January 1, 2024 through December 31, 2024, Pershing paid Stephens the following revenues: Interest based on investor free credit balances of $1,900,734 • A short interest rebate of $1,714,766 • • Margin interest credit of $836,256 • Active account and basis point credits of $1,563,496 • Non Purpose Loan interest of $617,507 • Silver Account (i.e. checking account) fee of $35,750 • Fee Income-Pershing-Legal/Transfer $7,600 • Pershing-Money Market Invesco ATRR $243,432 Where Stephens receives compensation from Pershing, this presents a conflict of interest because Stephens and your FC or IAR have a greater incentive to make available, recommend, or make investment decisions regarding investments and services that provide additional compensation over those investments and services that do not. ADV Part 2A March 31, 2025 22  The agreement between Stephens and Pershing is for an initial term of 10 years effective November 15, 2019, and it provides for a substantial termination penalty in the event Stephens terminates the Clearing Agreement prior to the end of the initial term. At the outset of the Clearing Agreement, the termination penalty was $15 million, and it declines $2 million each year to $5 million in years 6 through the end of the Clearing Agreement. The termination penalty serves as a disincentive for Stephens to terminate the Clearing Agreement in the event Stephens or its clients have a negative experience with Pershing or if Stephens believes another firm offers superior service. This creates a conflict of interest in that it could influence Stephens’ decision to remain with Pershing even though it may be in the best interest of Stephens or its clients to terminate the Clearing Agreement. You should only use the cost basis information provided on your custodial account statements for tax reporting purposes. Pershing’s mailing address: Pershing LLC; One Pershing Plaza; Jersey City, New Jersey 07399. For IRA and other retirement accounts, Pershing may charge termination fees pursuant to an adoption agreement you enter into with Pershing, which authorizes Pershing to act as the IRA custodian for Internal Revenue Service purposes. Pershing may resign at any time as the IRA custodian and then you have the right to appoint a successor IRA custodian (Successor). Where an unaffiliated third party acts as custodian of account assets, Stephens does not have discretion to select where cash reserves will be held. The client and/or custodian will make the selection. ERISA and IRA Fees Fees charged by Stephens to accounts of ERISA or Internal Revenue Code-covered plans will comply with the limitations made applicable under ERISA or the Code. Where Stephens or an FC provides non-discretionary investment advice such as recommending the rollover of a 401k to an IRA account at Stephens, recommending opening an IRA account with Stephens, or recommending the transfer of an IRA from another firm to Stephens, this presents a conflict of interest since compensation will be paid to Stephens and the FC in connection with these services. In addition, Stephens charges different levels of fees on different investment services. Stephens has adopted policies and procedures to mitigate these conflicts, and to address provisions of and prohibitions under ERISA and the Code with respect to potential conflicts of interest and self-dealing. ERISA Section 408(b)(2) Disclosures You may be, or may be acting on behalf of, a pension plan governed by the Employee Retirement Income Security Act of 1974, as amended (ERISA). ERISA section 408(b)(2), requires most parties that provide services to employee benefit plans to disclose certain information to a responsible plan fiduciary. Generally, the service provider must disclose the services that it provides to the plan and the compensation that it expects to receive in connection with the services. Stephens’ disclosures are available at the following web address: www.stephens.com/ERISA408b2 If you are the responsible plan fiduciary, please view the disclosures on this website. If you are not the responsible fiduciary, please forward this information to the responsible fiduciary of the plan. Please review this website periodically for any required updates. Principal Transactions Pursuant to SEC Rule 206(3), Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing the capacity in which it is acting. As a practical matter, the above requirements impose delays on the time at which principal transactions can be effected for advisory accounts, and thereby can impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. Investment advisory clients are advised that they have the option to seek execution of transactions recommended by the FC or IAR through broker/dealers other than Stephens. However, on transactions executed through Stephens with ADV Part 2A March 31, 2025 23  Pershing, Stephens or Pershing will not charge a commission to the client, except when an underwriting issue in which Stephens participates is purchased for an account; in this case, the sales concession and underwriting fees are built into the offering price. Stephens will strive to obtain “best execution” of transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances. Transactions in securities in which Stephens acts as a principal will only be effected for clients subject to the client’s written consent to such transaction indicating the quantity and dollar amount of the securities being purchased or sold. If Stephens is acting as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a client. IPO Retail Client Allocations Although underwriting initial public offerings (“IPOs”) on behalf of corporate and other types of issuer clients is a regular part of Stephens’ investment banking business, the frequency, share price, number of shares available, and other characteristics of such offerings vary widely over time. For example, in some years Stephens may participate as an underwriter in no, or only a few, IPOs. Factors that limit IPO product availability to clients through Stephens include: • Market conditions that make raising capital through IPOs less favorable or unfavorable for issuers, such as periods of high market volatility or depressed share prices. • Alternative investment options for institutional and retail investors that impact overall demand for IPO investments. • Lack of or diminished investor interest in market sectors in which Stephens’ issuer clients operate. • The availability of capital through other sources such as the private equity marketplace or attractive debt financing alternatives. • Diminished financial strength and business prospects of particular issuer clients that make them poor candidates for IPOs. • Lack of specific business needs of particular issuer clients for capital infusions. In addition, in many instances Stephens will only be a small participant in an IPO underwriting syndicate that is led by another firm or firms and, consequently, will have little or no control or influence over whether, or to what extent, shares in the IPO are allocated to retail accounts and, instead, are directed to institutional clients. The combination of these factors makes it impractical, if not impossible, for Stephens to determine how much and what types of IPO product will be available for allocation to its retail client accounts over any extended time period. That, in turn, effectively precludes Stephens from utilizing any type of rotational allocation system designed to ensure that all of its retail client accounts are treated equitably. Instead of attempting to allocate shares equitably across all retail client accounts, Stephens bases its share allocation decisions on an account-by-account methodology taking into consideration multiple factors, including the following: • The number of shares available in the IPO for allocation to Stephens’ retail clients. • The customary desire of Stephens’ issuer clients to avoid small retail allocations to numerous accounts, which would increase the cost and administrative burden of communicating and dealing with unnecessarily large numbers of investors. • Share allocation requests received by the Stephens syndicate department from the FCs and IARs who manage the firm’s retail client accounts. • The level of sophistication of the FC or IAR submitting those allocation requests in evaluating and dealing with IPO investments. • The stated interest of a particular retail client in participating in IPOs, in general, or in a particular IPO, including the number of shares requested. • The suitability of the investment for the client, particularly if it is speculative in nature, as is sometimes the case in IPOs. ADV Part 2A March 31, 2025 24  • Whether the requested IPO allocation would result in an overconcentration of the security in the client’s account, resulting in lack of appropriate diversification. • Whether the IPO investment would be consistent with the investment strategy and objectives agreed to by the client and the FC or IAR. • Any applicable tax considerations. • Whether the client has adequate liquidity in the account, or otherwise, to fund the IPO investment. • Whether the FC or IAR is able to contact the client on a timely basis and obtain any documentation necessary to participate in the offering. • Whether based on the client’s prior investment practices or discussions with the FC or IAR, it appears likely that the client intends to quickly resell the shares in order to obtain short term trading profits as opposed to holding them in order to gain long term appreciation, sometimes referred to as “flipping.” Given the complexity and sometimes subjective nature of this analysis, and the fact that the applicability of these considerations may vary with respect to a particular retail client at any given time, Stephens does not attempt to ensure that the allocation of IPO shares across all of its retail client accounts is equitable and does not analyze the fairness of its allocation decisions over time. In practice, some retail client accounts will have far greater access to IPO allocations than others. In fact, based on past experience, only a very small percentage of Stephens’ retail clients will participate in IPOs. Nevertheless, clients who are interested in participating in IPOs or a particular IPO are encouraged to advise their FC or IAR of such fact. IPO Related Conflicts of Interest Flipping. Stephens has a long-standing policy of discouraging its FCs and IARs from allocating IPO securities to retail client accounts that appear likely to quickly resell the securities in order to obtain short term trading profits as opposed to holding them in order to gain long term appreciation. Excessive short term trading in the secondary market following an IPO has the potential of causing market disruption and depressing the price of the issuer’s securities, both of which would operate to the disadvantage of Stephens’ issuer clients. Accordingly, Stephens reserves the right to withhold IPO allocations to retail client accounts that have a history of flipping their IPO securities positions or advise their FC or IAR of their intent to flip the IPO securities they wish to purchase in a pending IPO. This policy creates a conflict of interest because, while it favors Stephens’ IPO issuer clients and Stephens’ long term interests as an underwriter, it may not be in the best interest of a retail client seeking to realize short term trading profits on the client’s IPO positions. In addition, Stephens may penalize clients who flip their IPO securities by reducing or eliminating IPO allocations to them in the future. Favoring Larger Allocations. Stephens’ issuer clients generally prefer that the underwriting syndicate avoid small retail allocations to numerous accounts, which would increase the cost and administrative burden of communicating and dealing with unnecessarily large numbers of investors. Major items of expense in that regard include the printing and mailing of large numbers of investor communications such as proxy statements and annual reports. Further, Stephens, itself, incurs higher transaction and administrative costs if smaller IPO allocations are spread over a larger number of accounts. This overall situation creates a conflict of interest with respect to Stephens’ handling of smaller accounts because larger allocations mean that they will have less opportunity to participate in IPOs and gain the IPO experience that would potentially qualify them for participation in more IPOs. This methodology also has the potential of increasing risk for IPO investors to the extent that larger allocations would be expected to result in more concentration with respect to these types of typically more speculative securities. Advisory vs. Brokerage Accounts. If a retail client has both an advisory and a brokerage account, it may be in the best interest of the client to purchase IPO securities in the brokerage account. The client would pay the same offering price for the securities irrespective of which type of account is selected for the purchase. However, in a brokerage account no additional charges (in the form of commissions) would be incurred until the time the securities are sold, while in an advisory account the client would incur assets under management fees that could exceed the amount of such commissions depending on the length of the holding period. The risk of this disadvantage occurring is increased by Stephens’ policy against flipping, which is designed to encourage longer holding periods. ADV Part 2A March 31, 2025 25  Offerings with Less Demand. Based on Stephens’ previously described allocation process, there is a potential that a retail account that does not frequently participate in IPOs may have a greater opportunity to participate in IPOs that prove to be in less demand, particularly if Stephens receives a relatively large allocation for placement with its retail clients. Although Stephens, and its FCs and IARs, have limited ability to predict client demand for an IPO in advance of the pricing and effectiveness of the offering, certain of the criteria utilized in allocating shares, such as previous IPO experience and favoring larger allocations, may result in more favorable allocations to larger, more experienced retail accounts in connection with high demand offerings. On the other hand, these factors would be expected to have less of an impact with respect to offerings where there is less demand from retail clients relative to the size of the retail allocation Stephens receives. It is likely, although certainly not guaranteed; that IPOs for which there is high demand relative to supply will perform better in the post-offering market place for at least some period of time. Clients That Do Not Have Access. Stephens relies primarily on its FCs and IARs to determine whether, and to what extent, their retail advisory clients are interested in participating in IPOs. Many accounts are simply too small to participate in IPOs when concentration and suitability factors are taken into consideration. And, in practice, only a small percentage of Stephens FCs and IARs regularly submit IPO allocation requests on behalf of their clients. In many instances, retail clients are participating in one or more of the Stephens Private Client Group’s advisory platforms providing for fee based, discretionary management by the FC , a firm investment committee or a third party money manager. The vast majority of FCs rely on these platforms to achieve appropriate asset allocation for their clients and typically do not offer their clients the opportunity to participate in IPOs. The same is also generally true with respect to the retail client accounts managed by Stephens Capital Management. Finally, Stephens FCs and IARs, in their discretion, may elect to offer IPO allocations to some clients but not others, and such decisions are unlikely to be reviewed by Private Client Group supervisors or Compliance Department personnel. Given these circumstances, retail clients interested in participating in IPOs should advise their FC or IAR of such fact. These platforms provide for low cost, level fee charges to clients, and Stephens is not allowed to accept any other compensation with respect to the handling of the account, including the compensation it would receive in connection with the sale of IPO securities. Accordingly, Stephens does not allow these types of accounts to participate in IPOs. D. Pre-Paid Advisory Fees In some programs offered by Stephens the client is required to pre-pay the advisory fees. Generally, these fees are billed monthly, though in limited circumstances they may be billed quarterly. Under these programs, Stephens is typically compensated based on a percentage of the value of the assets in each advisory account. You pay a single asset-based fee, charged monthly or quarterly, which covers the services provided by Stephens. Advisory fees apply to standard accounts and include investment advice, securities execution fees, certain custodial services, associated account reports and investment portfolio reports. This is a wrap fee. The maximum annual fee rate for the SAS and the MAP programs is 2%. The maximum annual fee rate for all other pre-paid wrap fee advisory accounts is 2.5%. A minimum fee is assessed per account. Fees are negotiable based on a number of factors including the type and size of the account and the range of services provided by the FC. In special circumstances, and with your agreement, the fee charged to you for an account may be more than the maximum annual fee stated in this section. When are Fees Paid and How Fees are Computed Fees Paid in Arrears SCM fees apply to standard accounts and include management, brokerage services, (1) custodial services, associated accounting reports and investment management reports. Only in special circumstances are the fees negotiable or otherwise varied from the above schedules. In the event a client’s account is closed between quarter-ends, fees will be prorated as of the date of termination. The fee is deducted from the client’s account by SCM quarterly unless otherwise agreed in writing. The fee for the period from the date assets are first credited to the account to the end of the then-current calendar quarter shall be determined by computing the average market value of cash and securities in the portfolio as of the close of ADV Part 2A March 31, 2025 26  business on the last day of each calendar month (that ends on or after the date assets are first credited to the account referred to above), and multiplying the resultant average market value by one-fourth of the applicable annual fee rate(s) indicated above, pro-rated for the percentage of the current calendar quarter during which the portfolio is under management. The fee for any subsequent calendar quarter shall be determined by computing the average market value of cash and securities in the portfolio as of the close of business on the last day of each calendar month, and multiplying the resultant average market value by one-fourth of the applicable annual fee rate(s) indicated above. If an account has a margin debit balance, the total market value of the account used in computing Stephens’ fee is the total market value of all eligible assets, and is not reduced by the margin debit balance. For example, an account with a total market value of $120,000 and a margin debit balance of $20,000 will have a net market value of $100,000. Stephens’ fee would be computed using the total market value of $120,000 times 1/4th of the applicable annual fee rate(s) adjusted by the time period. The following programs require fees to be paid in arrears: • Stephens Capital Management Discretionary (“SCMD”) • Stephens Capital Management Fixed Income (“FIS”) • Stephens Capital Management Non-Discretionary (“SND”) • Stephens Spectrum Program (“SSP”) • StephensChoice (“SC”) • Stephens Spectrum 401k (“SSK”) • Pension Management Trust Program (“PMT”) • Health Management Trust Program (“HMT”) Fees Paid in Advance The fee is payable monthly in advance. The fees will be deducted from the client’s account monthly in advance, unless otherwise agreed in writing. If a percentage fee is used, the initial fee is calculated from the date the account is turned over for trading “turnover date” of the advisory account to the end of the then-current calendar month. The fee is obtained by multiplying the market value of eligible assets placed in the account by 1/12th of the applicable annual fee rate(s), prorated for the remaining percentage of the then-current calendar month. A prorated fee will be charged when additional assets greater than $25,000 on a single deposit (or monthly aggregate) are placed in the account, in an amount determined by multiplying the market value of the eligible additional assets placed in the account by 1/12th of the applicable annual fee rate(s), prorated for the remaining percentage of the month. A prorated fee will be rebated when assets greater than $25,000 on a single withdrawal (or monthly aggregate) are withdrawn from the account, in an amount determined by multiplying the market value of the withdrawn assets from the account by 1/12th of the applicable annual fee rate(s), prorated for the remaining percentage of the month. If an account has a margin balance owed, the market value of the account used in computing Stephens’ fee is the total market value of all eligible assets, and it is not reduced by the margin debit balance. For example, an account with a total market value of $120,000 and a margin debit balance of $20,000 will have a net market value of $100,000. Stephens’ fee would be computed using the total market value of $120,000 times 1/12th of the applicable annual fee rate(s) adjusted by the time period. In the event a client’s account is closed before month-end, fees will be prorated as of the date of termination. The following programs require fees to be paid in advance: • Professional Wealth Management (“PWM”) ADV Part 2A March 31, 2025 27  • Stephens Advisor (“SA”) • Stephens Allocation Strategies (“SAS”) • Stephens Managed Assets Program (“MAP”) • Stephens Unified Managed Account (“UMA”) • Stephens Retirement Solutions (“RSP”) • Stephens Retirement Access (“SRA”) E. Compensation for the Sale of Securities and Investment Products Stephens does not charge clients brokerage commissions for securities trades executed through Stephens with Pershing for the client’s account in any of the offered wrap programs listed above. Therefore none of our personnel receive revenues based on commissions from the purchase or sale of securities for those accounts. For mutual fund investments, fees are also charged by the mutual fund as more fully described in the mutual fund’s prospectus. Some of the fees charged by the mutual funds are paid to Stephens by the mutual fund. See Item 5.C for further discussion. Generally outside managers in the MAP program either provide Pershing with their model portfolio or direct their trading to Pershing for execution. In both of these situations, Pershing executes these trades at no additional charge to the clients because execution charges are included in the wrap fee the client pays Stephens. The number of managers in the MAP program that direct trades to other broker dealers can change as managers are added or removed from the program. The following equity/balanced strategies in the program have the ability to send trades for execution to broker-dealers other than Pershing, and trades executed away from Pershing will result in commission charges to Stephens’ clients in addition to the wrap fee the client paid to Stephens. These additional charges affected the net performance for the clients’ accounts. In the MAP program, certain third party managers can trade away from Pershing or Stephens in order to achieve best execution or other reasons. When the manager trades away this results in additional transaction charges being incurred by your account which are in addition to the advisory wrap fee you pay Stephens. The Managers/strategies which traded away from Stephens or Pershing in the last two years are: Franklin Templeton All Cap Blend Balanced Portfolios (MDA0-Balanced) Franklin Templeton Appreciation Balanced Portfolios Franklin Templeton Appreciation Balanced Tax-Favored Portfolios Franklin Templeton Balanced Income Portfolios Legg Mason Balanced Income Taxable (70/30) Legg Mason Balanced Income with Municipals Legg Mason Balanced Income With Municipals (70/30) Franklin Templeton All Cap Growth Balanced Portfolios Franklin Templeton Custom MDA Portfolios Franklin Templeton Global All Cap Blend Balanced Portfolios (MDA8-Balanced) Franklin Templeton Large Cap Growth Balanced Portfolios Nuveen Preferred Securities The average cost of the execution charges during this period was $0.00 to $0.05 cents per share. Generally, Sub-Advisors in the UMA program either provide Pershing with their model portfolio or direct their trading to Pershing for execution. In both of these situations, Pershing executes these trades at no additional charge to the clients because execution charges are included in the wrap fee the client pays Stephens. However, to achieve best ADV Part 2A March 31, 2025 28  execution and for other reasons, Non-Model Sub-Advisors have the ability to trade away from Pershing. When Non- Model Sub-Advisors trade away from Pershing, clients will incur additional costs for fixed income securities. The additional fees are per bond or on a per transaction basis which are embedded in the net price you receive. The number of Non-Model Sub-Advisors in the UMA program that direct trades to other broker-dealers can change as Non-Model Sub-Advisors are added or removed from the program. Item 6 Performance-Based Fees and Side-By-Side Management Stephens typically charges clients an investment advisory fee based on the value of the assets in the client’s account. On occasion, Stephens enters into performance fee arrangements with appropriate clients as discussed below. Only certain clients qualify for performance fee arrangements which compensate Stephens based, in part, on the performance of the client’s account. All fees are negotiable and vary depending on the size of the investment, the nature of the services to be rendered by Stephens to the client, and other factors. Performance fees are typically invoiced annually. Stephens only enters into performance fee arrangements with certain clients which are eligible to enter into these arrangements as defined in Rule 205-3 under the Investment Advisers Act of 1940 and in accordance with the requirements set forth in the applicable laws, rules and regulations, and these arrangements are negotiated with the client on an individualized basis. The performance fee arrangement could create an incentive for Stephens to seek to maximize the investment return by making investments that are subject to greater risk, or are more speculative, than would be the case if Stephens’ compensation were not based upon the investment return or could create an incentive for Stephens to seek to limit investment returns by pursuing investments with reduced risk. With a performance fee arrangement Stephens’ fee is, in part, contingent upon the returns on the client’s assets, which is computed based upon unrealized and realized appreciation or depreciation of client’s assets. This gives Stephens an incentive to favor performance fee accounts with investment opportunities and therefore creates a conflict of interest for Stephens. Accounts participating in a performance fee arrangement may pay Stephens more compensation, or less compensation, when compared to standard fee rates. Performance fee arrangements may not be available for all investment accounts and must be approved by Stephens on a case-by-case basis. Performance fee rates are negotiable. A client may negotiate a base fee rate, performance fee rates, an index to be used to calculate the performance fee, or the use of no index in calculating the performance fee. Any performance fee that Stephens charges is intended to comply with Rule 205-3 and other applicable requirements under the Investment Advisers Act of 1940 (the “Adviser’s Act”). Stephens has an incentive to favor accounts which it charges a performance fee over other types of client accounts by allocating more profitable investments to performance fee accounts or by devoting more resources toward the accounts’ management. Stephens seeks to mitigate the potential conflicts of interest which arise from managing accounts that bear a performance fee through its policies and procedures, including those related to investment allocation, and by complying with the provisions of Rule 205-3 as stated above. Stephens has discretion not to accept these arrangements. Item 7 Types of Clients Stephens’s advisory programs are available to individuals, banks, foundations, pension and profit sharing plans, trusts, IRA’s, endowments, corporations, partnerships and other entities requiring investment advisory services. Many of Stephens’ clients are high net worth individuals. We provide investment advice to individuals, trusts, to boards and retirement systems for various governmental pension and retirement plans, to corporate pension and retirement plans, to various foundations and private entities. Additionally, Stephens advises wrap fee accounts in various programs sponsored by affiliated and unaffiliated investment advisers. The sponsor establishes a minimum account size for each program, and you should refer to the ADV Part 2A March 31, 2025 29  sponsor’s wrap fee brochure for a discussion of minimum account sizes and whether the minimum account size can be waived. Only those clients we deem in our discretion suitable will be accepted into these programs. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Stephens utilizes street and independent sources for our research, but it is not the sole basis of our investment decision- making process. Other sources of information we utilize can include industry data obtained from subscription services, company filings, street research and models. We utilize these services for real-time news and pricing. We also utilize other independent research sources for quantitative reports that measure such things as price changes, growth rates, profitability, valuation, earnings surprises and earnings revisions. These quantitative reports are used to help identify new securities that meet our investment criteria and to monitor existing holdings. Investing in securities involves risk of loss that clients should be prepared to bear. B. Investment Strategies Stephens offers many investment strategies through our programs sponsored through SCM, SFIM and PCG. Our investment advisory services seek to tailor an investment program for the unique financial circumstances and objectives of a particular client. When we are engaged as an investment advisor, the client typically pursues one or more of our investment strategies. Clients may impose investment restrictions on their accounts, such as restrictions on investing in particular securities or types of securities or restrictions on investing in particular industries. All of the programs are more fully described in Item 4D and their respective ADV Part 2A, Appendix 1. SCM services discretionary and non-discretionary portfolios of equity, fixed income and alternative asset classes and provides asset allocation advice to clients. As an operating division of Stephens, an independent financial services firm, Stephens has a unique perspective on investing that enables SCM to spot opportunities that others miss and avoid the pitfalls of narrow, short-term thinking. Independence also affords us the flexibility to adapt our strategies to a changing financial environment while maintaining a focus on long-term growth and capital appreciation. SCM's IARs take into account both our clients' unique situations and the changing financial markets in developing investment strategies tailored to meet our clients' financial goals. PCG provides investment advisory services for discretionary and non-discretionary portfolios. Stephens has the flexibility to adapt strategies to a changing financial environment while keeping your goals and objectives in mind. A Full Range of Investment Solutions As a full-service financial services firm, Stephens offers access to a complete array of financial solutions designed to help you achieve your investment goals and objectives. Stephens can assist you in selecting and managing investment solutions that best fit your wealth management goals. These investment solutions can include: • Investment management and advisory services • Wealth management • Corporate executive services • Individual equities, mutual funds and exchange traded funds • Taxable and tax-exempt fixed income securities • Alternative investments • Insurance and annuities C. Risk of Loss The material risks associated with our strategies are: ADV Part 2A March 31, 2025 30  Alternative Investments -- Investing in alternative investments can be highly illiquid, is speculative and not suitable for all investors. Certain alternative investment products place substantial limits on liquidity and the redemption rights of investors, including only permitting withdrawals on a limited periodic basis and with a significant period of notice and may impose early withdrawal fees. Investing in alternative investments is intended for experienced and sophisticated investors only who are willing to bear the high economic risks of the investment. Investors should carefully review and consider potential risks before investing. Certain of these risks include: loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative practices; lack of liquidity, in that there may be no secondary market for the fund and none expected to develop; volatility of returns; restrictions on transferring interests; potential lack of diversification and resulting higher risk due to concentration of trading authority when a single advisor is utilized; absence of information regarding valuations and pricing; complex tax structures and delays in tax reporting; less regulation and higher fees than mutual funds; and advisor risk. Alternative investment products typically have higher fees (including multiple layers of fees) compared to other types of investments. Individual funds will have specific risks related to their investment programs that will vary from fund to fund. Debt Obligations - Investing in debt (bond) obligations entails additional risks, including interest rate risk such that when interest rates rise, the prices of bonds and the value of bond funds shares can decrease and the investor can lose principal value. Equity Market Risk - Overall stock market risks affect the value of the investments in equity strategies. Factors such as U.S. economic growth and market conditions, interest rates, and political events affect the equity markets. Foreign Debt Obligations - Investing in foreign debt obligations entails additional risks, including those related to regulatory, market or economic developments, foreign taxation and less stringent investor protection and disclosure standards. Foreign Securities - Investing in foreign securities presents certain risks that are not present in domestic securities. For example, investments in foreign and emerging markets present special risks including currency fluctuation, the potential for diplomatic and political instability, regulatory and liquidity risks, foreign taxation and differences in auditing and other financial standards. In addition to the greater exposure to the risks of foreign investing, emerging markets present considerable additional risks, including potential instability of emerging market countries and the increased susceptibility of emerging market economies to financial, economic and market events. Money Market Risk - An investment in a Money Market Fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although the fund seeks to preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in the fund. Yields will vary. Yield quotations more closely reflect the current earnings of the fund than the total return. Management Risk - Our judgments about the attractiveness and potential appreciation of a particular asset class, mutual fund or individual security may be incorrect and there is no guarantee that individual securities will perform as anticipated. The price of an individual security can be more volatile than the market as a whole and our investment thesis on a particular stock may fail to produce the intended results. Options Risk - Options involve risk and are not suitable for all investors. Small Cap and Mid Cap Company Risk - Investing in small cap and mid cap issuers involves a significantly greater risk than investing in larger, more established companies. The daily trading volume for Small Cap and Mid Cap issuers can be much lower than for more widely held, established companies. There may be periods when it is difficult to invest in or liquidate portfolio investments for our various investment strategies. This is particularly the case when breaking news on a company occurs or when significant market forces and events occur. In addition, small and mid- cap companies are more vulnerable to economic, market and industry changes. Because smaller companies often have limited product lines, markets or financial resources, or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than larger capitalization companies. ADV Part 2A March 31, 2025 31  Investors should only invest a portion of their total portfolios in these securities, and investors should be prepared to lose their entire investments. Certain Risks Associated with Cybersecurity With the increased use of technologies to conduct business, investment advisers, including Stephens rely in part on digital and network technologies (collectively, “cyber networks”). These cyber networks are susceptible to operational, information security and related risks and can be at risk of cyber-attacks. Cyber-attacks could seek unauthorized access to cyber networks for the purpose of misappropriating sensitive information, corrupting data, or causing operational disruptions. Cyber-attacks can potentially be carried out against the issuers of securities you have invested in, against third party service providers, or against Stephens itself by persons using techniques that range from efforts to circumvent network security, overwhelm websites, and gather intelligence through the use of social media in order to obtain information necessary to gain access to cyber networks. Although cyber-attacks potentially could occur, Stephens and Pershing maintains an information technology security policy and technical and physical safeguards intended to protect the confidentiality of internal data. Bank Sweep Program If you have on deposit through the Bank Sweep Program an amount of cash that exceeds the number of Banks multiplied by $250,000, the balances in excess of this amount will not be insured by the FDIC. In the event of a failure of a bank participating in the Bank Sweep Program, there may be a time period during which you may not be able to access your cash. If you have cash at a bank outside the Bank Sweep Program, this may negatively impact the availability of FDIC insurance for the total amount of your funds held within and outside the Bank Sweep Program. You are responsible for monitoring the total amount of deposits that you hold with any one Bank, directly or through an intermediary, in order to determine the extent of FDIC insurance coverage available to you on your deposits, including the Deposit Accounts. Nothing obligates you to participate in the Bank Sweep Program. You may receive a higher rate of return through products offered outside the Bank Sweep Program, including Money Market Funds offered through your account with Stephens and Pershing. Each Deposit Account constitutes a direct obligation of the Bank and is not directly or indirectly an obligation of Stephens or Pershing. Stephens and Pershing do not guarantee in any way the financial condition of the Banks or the accuracy of any publicly available financial information concerning such Banks. Stephens and Pershing are not responsible for any insured or uninsured portion of a Deposit Account. Item 9 Disciplinary Information Stephens voluntarily participated in the SEC’s Share Class Selection Disclosure Initiative, and on March 11, 2019 the SEC entered a Cease and Desist Order against Stephens in which Stephens neither admitted nor denied the allegations of the SEC’s Order. The Order alleged that Stephens did not fully disclose conflicts of interest related to the selection of mutual fund share classes for its advisory clients, and that Stephens purchased, recommended or held mutual fund share classes for client accounts which paid Stephens 12b-1 fees when less expensive share classes of the same funds were available which did not pay Stephens these 12b-1 fees. The Order directed Stephens to Cease and Desist from committing or causing any violations and any future violations of Sections 206(2) and 207 of the Investment Advisers Act of 1940 and ordered that Stephens be censured and pay disgorgement and prejudgment interest to advisory clients who held these more expensive mutual funds share classes in their advisory accounts. (IA Release No. 40-5196) In its capacity as a broker/dealer, Stephens has been subject to legal or disciplinary events in the ordinary course of its business, such as regulatory sanctions relating to compliance with broker/dealer trade reporting requirements and other regulatory actions. Item 10 Other Financial Industry Activities and Affiliations ADV Part 2A March 31, 2025 32  A. Other Business Activities In addition to Investment Advisory services, Stephens is registered with the SEC as a Broker/Dealer. Stephens provides services as appropriate and contemplated under these registrations. B. Stephens Industry Affiliations Stephens is a full service broker/dealer and investment bank. In addition to being registered with the SEC, Stephens is a member of the Financial Industry Regulatory Authority (“FINRA”), the New York Stock Exchange, Inc. (“NYSE”), the NYSE American LLC (“NYSE-AMEX”), the Municipal Securities Rulemaking Board (“MSRB”), the Investors’ Exchange LLC (“IEX”) and the Securities Investor Protection Corporation (“SIPC”). Stephens derives greater revenues from its broker/dealer and investment banking activities than it derives from its investment advisor activities. Affiliates of Stephens are also separately engaged in financial services businesses, including merchant banking, insurance and investment advisory businesses. C. Affiliations 1. Affiliated Mutual Funds Stephens may from time to time engage in transactions on behalf of clients with Hotchkis & Wiley Capital Management LLC (“H&W”) or with mutual funds advised by H&W. H&W is an investment adviser registered with the SEC in which entities under common control with Stephens hold an ownership interest. H&W provides investment advisory services to corporate, pension, public, endowment, foundation, mutual fund and other clients, and H&W also advises its own family of mutual funds. Stephens may also from time to time engage in transactions on behalf of clients with Stephens Investment Management Group LLC (“SIMG”) or with mutual funds advised by SIMG. SIMG is an investment adviser registered with the SEC in which affiliates of Stephens hold the entire ownership of voting securities. SIMG provides investment advisory services for separate account clients and for mutual funds known as the American Beacon Stephens Funds® or other funds which may be added from time to time. Additionally, SIMG serves as one of the investment advisors to the following multi-manager mutual funds using its SMID Select Growth Strategy or Small Cap Growth Strategy: • Vanguard Explorer™ Fund; and • Bridge Builder Small/Mid Cap Growth Fund; and • First Trust Multi-Manager Small Cap Opportunities ETF (MMSC) H&W advised mutual funds and SIMG advised mutual funds are offered through Stephens’ broker dealer services and/or investment advisory services as part of an investment program. Clients that invest in H&W advised mutual funds or in SIMG advised mutual funds would bear a proportionate share of the fees and expenses of those funds including the management fees or other fees paid to H&W or SIMG. These fees and expenses include commissions or fees, if any, paid to Stephens in connection with portfolio transactions. Please refer to each mutual fund’s prospectus for a full discussion of the fees and expenses of each mutual fund. 2. Stephens Sponsored Wrap Fee Program Stephens sponsors the Stephens Small-Mid Cap Core (“SMID Core”) Growth Program which is a wrap fee program sub-advised by SIMG that follows its SMID Core Growth Model. FCs or IARs are not financially incentivized to place clients in the SMID Core Growth Program versus any other wrap program or platform available at Stephens. However, a portion of the SMID Core account fees, generally representing twenty to fifty percent (20%-50%) of SMID Core fees, will be paid to SIMG for its portfolio management services, pursuant to a sub-advisory agreement between Stephens and SIMG. SIMG and Stephens share common ownership which benefits from the compensation generated to SIMG as the result of a client investing in the SMID Core Growth Program. Depending on the level of trading, the value of the account, and types of securities purchased or sold, clients may be able to obtain transaction execution at a higher or lower cost if purchased separately at Stephens or SIMG than through this wrap fee program. ADV Part 2A March 31, 2025 33  3. Affiliated Investment Management Activities Certain investment strategies offered by SIMG have been selected for inclusion in the Private Client Group’s (“PCG”) Managed Assets Program (“MAP”). Sub-Advisors and strategies may only participate in MAP if they have been approved by the MAP Investment Committee. The MAP Investment Committee employs a process for evaluating investment managers that includes both qualitative and quantitative factors. SIMG strategies participating in MAP are subject to the same due diligence and evaluation processes as sub-advisors or strategies that have no affiliation with Stephens. FCs are not financially incentivized to favor selecting SIMG strategies over non-affiliated sub-advisors or strategies. However, selection of an SIMG strategy in MAP generates compensation to SIMG, which shares common ownership with Stephens. 4. Other Affiliations Certain entities affiliated with Stephens or under common control with Stephens hold an ownership interest in Alex Brown Realty, LLC, a registered investment adviser. From time to time, Stephens offers to its clients securities sponsored by Alex Brown Realty, LLC. Stephens sometimes refers clients to Stephens Insurance, LLC, an affiliated insurance agency under common control with Stephens, for advice pertaining to products that are provided through Stephens Insurance, LLC, and FCs and IARs may be eligible, subject to regulatory and legal requirements, to receive referral fees for insurance business referred. Stephens Insurance, LLC, may refer prospects seeking investment advisory services to Stephens. If the referral results in a new account relationship, then a portion of the net revenue from such account may be paid to Stephens as a referral fee. This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. For further information that pertains to related persons of Stephens, please refer to “Other Potential Conflicts of Interest” following Item 18 below. D. Arrangements with related Investment Adviser or Investment Companies From time to time, Stephens and its FCs and/or IARs may recommend that clients invest in investment products that are affiliated with Stephens. Such arrangements are described in greater detail in Item 10.C above. Such a recommendation of affiliated investment products creates a potential conflict of interest because Stephens, its affiliates, and their beneficial owners may receive higher aggregate compensation than if clients invest in unaffiliated investment products. Stephens addresses this potential conflict through disclosure, including in this Brochure. Additionally, when acting as fiduciaries, Stephens FCs and IARs are required to recommend affiliated investment products only when they determine it is in the client’s best interest to do so. FCs or IARs are not financially incentivized to recommend Stephens- affiliated products over any other investment product available at Stephens. In no case are you under any obligation to purchase any products or services sold by us or our affiliates. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Investment Advisory Code of Ethics Stephens has adopted an Investment Advisory Code of Ethics (“Code”), which defines the requirements and expectations for the business conduct of all of its Investment Advisory employees, including employees of Stephens. Furthermore, all Stephens’ employees are expected to adhere to Stephens’ Mission and Values Statement and Code of Professional Conduct. The fundamental position of Stephens is that all aspects of its business are to be conducted in an ethical and legal manner in accordance with federal law and the laws of all states where the investment advisory divisions do business. In accordance with that position general principles apply: ADV Part 2A March 31, 2025 34  1. The interests of Stephens’ clients are our first consideration. Any personal securities transaction, which would be detrimental or potentially detrimental to any client account and any personal securities transaction, which is designed to profit by the market effect of any client account, must be avoided. 2. All personal securities transactions should be conducted in such a manner as to be consistent with the Code and to avoid actual or potential conflicts of interest or abuse of a Stephens’ employee’s knowledge of client information or client transactions. 3. Investment adviser personnel should not take inappropriate advantage of their positions. Information concerning the identity of security holdings and financial circumstances of clients is confidential. 4. Independence in the investment decision-making process is paramount. Accordingly, there are certain standards of conduct, which Stephens investment advisory employees follow to reduce potential conflicts with the interests of our clients. Stephens will provide a copy of the Code to any client or prospective client upon request. B. Conflicts of Interest Ownership Pursuant to SEC Rule 206(3), Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing the capacity in which it is acting. As a practical matter, the above requirements may impose delays on the time at which principal transactions may be effected for advisory accounts, and thereby may impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. Transactions in which Stephens acts as a principal will only be effected for clients subject to the client’s written consent to such transaction indicating the quantity and price of the securities being purchased or sold. If Stephens is acting as a market-maker or otherwise as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a client. American Beacon Stephens Funds® and Hotchkis & Wiley Funds (“Affiliated Funds”) are funds managed by affiliates of Stephens and/or advisors in which affiliates of Stephens have a substantial ownership interest. ERISA accounts and IRA accounts are generally prohibited from investing in these Funds. Other advisory accounts may invest in the Affiliated Funds in an appropriate amount if: (1) the manager and the client determine that the investment is suitable for the account, and (2) the client signs an Affiliate Funds Consent Letter (“Consent Letter”) prior to directing the purchase of the affiliated fund shares. Hotchkis and Wiley Limited (“HW-UK”), a wholly-owned subsidiary of H&W, is a private limited company incorporated in England and Wales. HW-UK is an appointed representative and tied agent of Arlington Group Asset Management Limited (AGAM) since March 1, 2016. AGAM is authorized by the Financial Conduct Authority to carry out regulated activities. The Chief Executive of HW-UK is also an appointed representative of AGAM and may carry on certain regulated activities in Europe. For further discussion on Affiliated Funds, see 10C and 10D. C. Stephens Personal Trading Stephens’ personnel may not participate in IPOs. All employees are required to maintain their personal accounts and accounts in which they have a beneficial interest at Stephens unless the account has been specifically exempt in writing from this requirement. Stephens’ employees are required to provide copies of all of their trade confirmations and brokerage account statements to Stephens’ Compliance Department in order to permit the monitoring of compliance with personal trading policies and restrictions. Additionally, employees are required to report all personal securities transactions no less than quarterly. Stephens’ Code requires employees to report violations of the Code to Stephens Chief Compliance Officer. D. Conflict of Interest with Personal Trading and Client Trades ADV Part 2A March 31, 2025 35  To minimize potential conflicts of interest, advisory personnel who determine or approve what recommendations will be made for client accounts will not participate in Stephens’ trading activities and will not know what trading strategies are employed for its proprietary accounts. It should be noted, however, that Stephens allows purchases to be made in the marketplace by its employees of securities owned by any client account, provided that such purchases are made in amounts consistent with the normal investment practice of the person involved. Such purchases must be made after the investment advisory accounts managed by such employee (or in the management of which such employee participates has completed its transactions in such securities. Under certain circumstances, employee transactions may be permitted prior to full completion of investment advisory division’s transactions. Such exceptions require prior approval of the Chief Compliance Officer or his designee and will only be granted after considering factors such as the time element involved in filling the order, market considerations, etc. Item 12 Brokerage Practices A. Broker-dealers Selection or Recommendations Stephens’s investment advisory client accounts typically trade through Stephens with Pershing. In most of Stephens’ investment advisory programs, brokerage commissions for trades executed by Stephens with Pershing for investment advisory accounts are included in the investment advisory fee and no separate brokerage commissions are charged by Stephens for the execution of such trades. Clients may arrange to execute transactions in their accounts through other broker-dealers. In such event, all commissions and other charges of the other broker-dealers will be borne by the account or the client, and will not be borne by Stephens. 1. Research and Other Soft Dollar Benefits Stephens does not enter into arrangements with other broker-dealers whereby it receives free research in exchange for the placement of a specified amount of client trades. 2. Brokerage for Client Referrals Stephens typically does not recommend other broker-dealers to our clients. Stephens’s client accounts typically trade through Pershing. In most of Stephens’ investment advisory programs, brokerage commissions for trades executed by Pershing for investment advisory accounts are included in the investment advisory fee and no separate brokerage commissions are charged by Pershing or Stephens for the execution of such trades. Clients may arrange to execute transactions in their accounts through other broker-dealers. In such event, all commissions and other charges of the other broker-dealers will be borne by the account or the client, and will not be borne by Stephens. 3. Directed Brokerage Investment advisory clients will be advised that they have the option of seeking execution through broker/dealers other than through Stephens with Pershing. From time to time some of Stephens’ clients may wish to direct Stephens to route their entire portfolio transactions through a particular broker-dealer at a rate agreed upon between the client and such broker-dealer. In such cases, Stephens typically does not negotiate commission rates with such broker-dealers. Clients are free to choose or change broker-dealers at their discretion unless there is reason to believe the chosen brokerage firm cannot offer adequate service. In such an event, Stephens might be unable to accept management of the account. a. Directed Brokerage A client who directs Stephens to use a particular broker-dealer should carefully consider whether such a directed brokerage arrangement could result in additional costs or disadvantages to it. These costs and disadvantages may include paying higher commissions and receiving less favorable executions. Accordingly, the client should satisfy itself that the broker-dealer it directs us to route their trades to can provide adequate price and execution of transactions. All commissions and other charges of the directed broker-dealers will be borne by the account or the client, and will not be borne by Stephens. A client that directs us to use a particular broker-dealer may also be subject to certain disadvantages regarding allocation of new issues and aggregation of orders. See below. Accounts custodied at brokerage firms that do not permit Stephens to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so ADV Part 2A March 31, 2025 36  restricted. In determining whether to direct Stephens to use a particular broker-dealer, the client may wish to compare the possible costs or disadvantages of such an arrangement. b. Aggregation of Client Transactions Stephens may determine in particular circumstances that, while it would be both desirable and suitable that a particular security or other investment be purchased or sold for the account of more than one of Stephens’ client accounts, there is a limited supply or demand for the security or other investment. Under such circumstances, Stephens will seek to allocate the opportunity to purchase or sell that security or other investment among those accounts on an equitable basis; and Stephens will not be required to assure equality of treatment among all of its clients (including that the opportunity to purchase or sell that security or other investment will be proportionally allocated among those clients according to any particular or predetermined standards or criteria) or to undertake to make investment opportunities offered or provided to clients of other divisions of Stephens or to clients of other representatives of Stephens available to Stephens or to clients of the representative assigned to client’s account, including client. Stephens may aggregate purchase or sale orders in a particular security for client’s account with orders for other clients’ accounts when appropriate. However, Stephens is under no obligation to aggregate orders. Where, because of prevailing market conditions, it is not possible to obtain the same price or time of execution for all of the securities or other investments purchased or sold for client’s account in an aggregated order, Stephens may average the various execution prices and charge or credit client’s account with the average price. Item 13 Review of Accounts Supervision and Review of Accounts Primary responsibility for the supervision of these accounts lies with the applicable Stephens’ Supervisory Principal. The Supervisory Principals conduct periodic reviews of activity in selected advisory accounts, considering suitability of transactions and general performance. Further considerations are levels of activity, timing of transactions in relationship to research recommendations, transactions in restricted securities, unprofitability, concentration in one security and individual objectives and needs of the client based on information provided by the client. In addition to periodic reviews, designated principals at Stephens’ home office make quarterly reviews of the investment performance and investment strategy of selected accounts. The reviewers may refer accounts to the Compliance Department for further analysis if necessary. Reviewers are not assigned accounts by any formula or numerical standard. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b-1 fees are received on client advisory holdings, these will be rebated to the advisory client. When Stephens executes a transaction for you through Pershing’s order execution system, you will receive a written or electronic confirmation of the transaction which provides information regarding the transaction. You will also receive a written monthly account statement if you had activity in your account that is custodied by Pershing during the month, which will detail the activity and the positions in your account. If you have not had any activity during the month and you have positions in your account, you will receive a written quarterly account statement, which details the positions in your account. You may waive the receipt of account statements or confirmations after each trade in favor of e- delivery via https://stephensaccess.netxinvestor.com/nxi/welcome. You may also receive mutual fund prospectuses, where appropriate. In addition, we provide account reports and/or statements for client accounts reflecting account holdings and account performance on a quarterly basis. Item 14 Client Referrals and Other Compensation Neither Stephens nor any of our employees receives any sales awards or other prizes from any non-affiliated outside parties for providing investment advice to our clients. Stephens may enter into referral arrangements with its affiliates or between divisions of the Firm. This includes referrals to Stephens of prospective clients seeking investment advisory services. If the referral results in a new account ADV Part 2A March 31, 2025 37  relationship, then a portion of the net revenue from such account is paid to such entity or division as a referral fee, and such entity or division may pay some portion of the fee to the referring person. This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. Such arrangements are conducted in accordance with the Marketing Rule, as applicable, and the Advisers Act generally. FCs and IARs are eligible to receive referral fees for referring eligible clients to the Stephens Investment Banking division. For eligible investment banking referrals, referring parties are eligible to receive compensation as a percentage of net income earned by Investment Banking. Therefore, FCs and IARs are incentivized to refer clients to the Investment Banking division. Any such compensation to the FC or IAR is at the discretion of the Firm. Item 15 Custody Effective November 15, 2019, Stephens entered into a fully disclosed clearing arrangement with Pershing wherein Pershing provides certain recordkeeping and operational services to Stephens and to Stephens’ clients. Pershing will execute and clear all transactions, maintain sole custody of assets in your account and perform custodial functions, including, but not limited to, crediting interest and dividends. You shall retain ownership of all cash, securities and other assets in your account. Transactions in your account may incur additional transaction fees, commissions, and/or other charges. By selecting Stephens as your brokerage/advisory firm, Stephens will open a custodial account with Pershing as the clearing firm, a subsidiary of the Bank of New York Mellon Corporation, One Pershing Plaza, 4th Flr – Jersey City, NJ 07399. Your assets will be held in this account. Pershing will send your account statements, which you should carefully review. In addition to the account statements Pershing sends you, we may send you a quarterly performance report which among other things, lists your account holdings and performance. You should compare our report to the account statements you receive from Pershing. In the event of any discrepancy between our report and any statement you receive from Pershing regarding the same investment, you should rely on the statement from Pershing. The information contained in your account statements and reports is obtained from sources believe to be reliable but have not been independently verified. Only the statement of the custodian of the account assets should be considered the official record of account assets, and only the statement of the custodian of the account assets should be relied upon for tax reporting purposes. If Pershing is not the custodian of assets, statements or reports may not be provided unless requested. If Pershing is the custodian of the account assets, then your Pershing brokerage account statement is the custodial statement for the account assets. Please notify us promptly if you do not receive an account statement on at least a quarterly basis from the custodian(s) of all account assets. You should only use the cost basis information provided on your custodial account statements for tax reporting purposes. For IRA and other retirement accounts, Pershing may charge termination fees pursuant to an adoption agreement you enter into with Perishing, which authorizes Pershing to act as the IRA custodian for Internal Revenue Service purposes. Pershing may resign at any time as the IRA custodian and then you have the right to appoint a successor IRA custodian (Successor). Item 16 Investment Discretion Investment or Brokerage Discretion Clients that desire to give Stephens investment discretion execute an Investment Management Agreement with Stephens which states that Stephens will have investment discretion in the client’s account. Stephens discretionary account programs, give the client an opportunity and authority to instruct Stephens of limitations applicable to the account, i.e., undesirable investments, asset allocations, etc. The FC or IAR under the Programs will supervise and direct the investments of an account subject to such limitations as the client may impose in writing. Item 17 Voting Client Securities ADV Part 2A March 31, 2025 38  Policies and Procedures for Proxy Voting Proxy voting on securities managed by a Sub-Adviser is to be directed by the Sub-Adviser managing such investment. Proxy voting on securities managed pursuant to a model portfolio provided by a Sub-Adviser is generally directed by such Sub-Adviser or by Stephens. For proxy voting directed by Stephens, it is Stephens’ policy to vote proxies on securities that are owned in an account and held in custody for the account by Pershing and to utilize Investment Advisory policies and procedures, which are reasonably designed to vote client securities in the best interests of the client and to address how potential conflicts of interest are handled. Stephens’ proxy voting policy is to vote in favor of actions recommended by the insurer’s Board of Directors of the issuer, unless the FC disagrees with the proposed action and elects to vote the shares against the recommendation of the Board of Directors. If there is not a Board of Directors recommendation on a proposed action, then the FC will determine whether to vote for, against or abstain. If the client chooses to have their securities custodied away from Stephens it will be the responsibility of the client to vote or to arrange for the voting of their proxies. Stephens will make available information of the firm’s proxy voting policy and procedures including information regarding how Stephens voted proxies, if requested. In response to any request as to how the client’s proxies were voted, the Chief Compliance Officer – Investment Advisory would provide the information to the client. Procedures Stephens’ procedures to implement the Firm’s proxy voting policy, is as follows: a. Voting Procedures • Proxy materials are received on behalf of clients in Stephens’ Reorganization Department (“Reorg. Department”); • A Proxy Voting Notice which includes a link to the proxy voting materials is sent by the Reorg Department via e-mail to the respective advisory area. This proxy Voting Notice will be used to instruct the Reorg Department as to how to vote the shares; • Stephens will vote the proxy through the Reorg Department in accordance with applicable voting guidelines, either by electronically voting or by mailing the proxy in a timely and appropriate manner. • • Unless the responsible FC, IAR or Stephens loses confidence in management of the issuer or the client directs the vote, Stephens will vote the shares as recommended by the Board of Directors of the issuer If there is not a Board of Directors recommendation on a proposed action, then the FC or IAR will determine whether to vote for, against or abstain. b. Proxy Voting Guidelines If securities are custodied elsewhere the client or custodian is responsible for voting. In a Sub-Advisory relationship the Sub-Advisor is responsible to vote the client’s proxies. • Stephens, if custodied at Pershing, is responsible for voting proxies. • • c. Conflicts of Interest • On an annual basis Stephens will disclose to affected clients any identified potential material conflicts of interest by providing a list of said conflicts electronically or by mail. • Where Stephens has identified a specific potential material conflict of interest relating to one or more matters to be voted on by shareholders, Stephens: (1) will notify affected clients of the potential conflict of interest, (2) will disclose how the proxy will be voted absent a voting direction from the client, and (3) will give affected clients the opportunity to vote the proxy themselves. • Stephens will maintain a record of the voting resolution of any conflict of interest. ADV Part 2A March 31, 2025 39  From time to time there may also be a variety of corporate actions or other matters for which shareholder action is required or solicited and with respect to which Stephens may take action that it deems appropriate in its best judgment except to the extent otherwise required by agreement with the client. These actions include, for example and without limitation, responding to tender offers or exchanges, bankruptcy proceedings and proposed class action settlements. However, Stephens will have no power, authority, responsibility or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in the client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. Stephens Advisor, Stephens Retirement Access, Stephens Retirement Solutions and the Stephens Capital Management Non-Discretionary Program Proxy Procedures Stephens will not take any action with respect to the voting of proxies solicited by or with respect to the issuers of securities in which assets of the client may be invested from time to time, except to provide proxy materials to Client. Stephens will have no power, authority, responsibility or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in the client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. Item 18 Financial Information Stephens does not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance and, thus, has not included a balance sheet of its most recent fiscal year. Stephens is not aware of any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to our clients. Other Potential Conflicts of Interest Stephens is a diversified financial services company that directly or through affiliates provides a wide variety of investment banking, securities, insurance and other investment-related services to a broad array of clients. These relationships could give rise to potential conflicts of interest. Any of the following types of transactions could present a potential for a conflict of interest. a) Client account assets can be invested in interests of money market funds, mutual funds, other investment companies, privately offered investment funds and other collective vehicles (collectively, “Fund Vehicle”) for which Stephens or its affiliates acts as investment advisor, sponsor, administrator, distributor, selling agent, or in other capacities (“Affiliated Funds”). In addition, client account assets can be invested in interests of Fund Vehicles for which Stephens or its affiliates do not act as investment adviser, sponsor, and administrator or in other capacities. Stephens or its affiliates receive fees for services provided to such Fund Vehicles, which often include (but are not limited to) fees payable under a plan adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (“12b-1 fees”) and fees paid to compensate Stephens for providing administrative services, distribution services, shareholder services, investment advisory services or other services to or for the benefit of such Fund Vehicles, excluding retirement programs. Stephens as a dually-registered broker-dealer is paid the retail 12b-1 fees for brokerage mutual fund investments. Where 12b-1 fees are received in advisory, IRA and ERISA accounts, these fees are rebated to the client’s advisory account. b) From time to time, client account assets are invested in transactions that involve or constitute a purchase, sale or other dealings with securities or other instruments for which (i) Stephens, (ii) an affiliate or employee of Stephens, (iii) an entity in which Stephens or an affiliate has a direct or indirect interest, or (iv) another member of a syndicate or other intermediary (where an entity referred to in (i), (ii), or (iii), above is or was a member of the syndicate), has acted, now acts, or in the future may act as an underwriter, syndicate member, market maker, dealer, broker, principal, agent, research analyst or in any other similar capacity, whether the purchase, sale or dealing occurs during the life of the ADV Part 2A March 31, 2025 40  syndicate or after the close of the syndicate. Stephens has an incentive to favor the securities of issuers for which it provides such services over the securities of issuers for which Stephens does not provide such services. Your FC or IAR also receives more money if you buy these investments. Although underwriting initial public offerings (“IPOs”) on behalf of corporate and other types of issuer clients is a regular part of Stephens’ investment banking business, the frequency, share price, number of shares available, and other characteristics of such offerings vary widely over time. For example, in some years Stephens may not participate as an underwriter, or in only a few, IPOs. For factors that limit IPO product availability to clients through Stephens see Item 5(C) Other types of Fees and Expenses Clients May Pay /IPO Retail Client Allocations/IPO Related Conflicts of Interest for more detail. c) Stephens, or any other broker-dealer that is or may become affiliated with Stephens (the “Affiliated Brokers”), is expected to act as broker or dealer to execute transactions on behalf of client’s account. Client will not be charged a separate fee for brokerage services provided to the Account by Affiliated Brokers. d) Stephens or its affiliates sometimes effect transactions for the client’s account with other accounts for which Stephens or an affiliate provides investment advisory services (“Cross Trades”). Such Cross Trades are intended to enable Stephens to purchase or sell a block of securities at a set price and possibly avoid an unfavorable price movement that may be created through entrance into the market with such purchase or sell order. Stephens typically receives compensation from other accounts involved in a Cross Trade. e) Subject to applicable regulations, Stephens or its affiliates sometimes execute “Agency Cross Transactions” for the client’s account. Agency Cross Transactions are transactions where Stephens, or any affiliate of Stephens, acts as broker for both the Client’s account and the other party to the transaction. In such transactions, Stephens, or any of Stephens’s affiliates acting as broker, receives commissions from the other party to such transaction, to the extent permitted by law, in addition to its customary investment management or advisory fee for the client’s account. f) Clients of other divisions of Stephens or clients of other advisory representatives of Stephens or Stephens, its principals, employees, affiliates and their family members, sometimes hold, and sometimes engage in transactions in, securities purchased or sold for the client or about which Stephens gives or has given client advice. The client’s account may purchase as investments securities of companies with which Stephens or its affiliates maintain investment banking relationships or other relationships or securities of companies in which Stephens or its affiliates have an ownership or other investment interest. h) Subject to applicable law, Stephens sometimes pays fees to, and/or shares revenues with, affiliates or non-affiliates in connection with referrals for investment advisory accounts. For additional information regarding referral fees, please see Item 14 above. i) Stephens, or its affiliates, may provide more than one type of service to the client (or a related organization), including (but not limited to), investment management services, investment advisory services, financial advisory services, underwriting services, placement agency services, investment banking services, securities brokerage services, securities custodial services, insurance agency services, insurance brokerage services, administrative services or other services, or any combination of services, all on such terms as may be agreed between Stephens (or its affiliate) and the client (or its related organization). j) Other divisions and other advisory representatives of Stephens perform investment advisory services for clients other than the client and such other divisions or other advisory representatives of Stephens give advice or take action with respect to other clients that is similar to or different from the advice given or action taken for the client’s account, in terms of securities, timing, nature of transactions and other factors. Stephens will, to the extent practicable, attempt in good faith to allocate investment opportunities among its clients, including the client, on a fair and equitable basis. However, other divisions and other advisory representatives of Stephens will not undertake to make any recommendation or communication to client with respect to any security which such other divisions or advisory representatives may purchase or sell (either as principal or for any other client’s account) or recommend to any other ADV Part 2A March 31, 2025 41  client, or in which such other divisions or advisory representatives, or their respective principals, employees, affiliates or their family members, may engage in transactions. k) Both advisory and brokerage clients of Stephens have the ability to borrow money against the collateral value of their accounts with non-purpose loans arranged through Stephens with third party banks. Stephens receives a fee which is paid by third party banks in an amount which varies but can be up to 1.35% of the monthly outstanding balance of the client’s loan. Part of the administrative fee is passed along to Stephens Financial Consultants, and this can create a conflict of interest. Since Stephens has not compared rates available elsewhere, clients may be able to obtain lower interest rates on their loans through other banks. l) Stephens and Pershing and IntraFi receives fees and benefits for services provided in connection with the Bank Sweep Program. Stephens offers the Bank Sweep Program as a service and is not obligated to offer you this or any sweep product or to make available to you a sweep product that offers a rate of return that is equal to or greater than other comparable products or investments. Stephens has an economic incentive to make available to our clients sweep options that are more profitable to us than other sweep options. Each Bank will pay Stephens a fee equal to a percentage of the average daily deposit balance in your Deposit Accounts at the Bank. Because the Banks pay different amounts, the compensation paid to Stephens will vary from Bank to Bank. Because the interest rates paid to clients are subject to tiers based on the aggregate value of accounts with the client’s Household Balance, Stephens’s compensation rate is higher on client’s cash in lower interest rate tiers and lower on client’s cash balances in higher rate tiers. Stephens may reduce its fee and may vary the amount of the reductions between clients. The interest rate applicable to your Deposit Accounts is determined by the amount of interest participating banks are willing to pay on the aggregate balance of the deposits minus (i) the fees paid to Intrafi Network, LLC, as administrator, (ii) the fees paid to Pershing for its services, and (iii) the fees paid to Stephens. Stephens retains and exercises the right to negotiate its own fee and may reduce or increase its fee. Because an increase in fees to Stephens reduces the effective amount of the interest rate that is ultimately paid to customers, Stephens has a conflict of interest with regard to the Bank Sweep Program. The rate tier applicable to your Deposit Accounts is determined based on your Household Balance as of the first business day following the fifteenth (15th) of the month. Stephens charges advisory accounts an investment advisory fee based on a percentage of client assets. In computing your investment advisory fee, cash balances in the Bank Sweep Program are included in the assets of your account when calculating the investment advisory fee earned by Stephens for management of your account. Therefore, Stephens is paid both its fee from the Banks on the Bank Sweep Program balance in your account, and, in addition, Stephens earns an investment advisory fee for your total balances in your account, including your balance in the Bank Sweep Program. This creates a conflict of interest, as Stephens earns more from Bank Sweep Program balances in investment advisory accounts than it would if such balances were held outside of the Bank Sweep Program or outside of the investment advisory account entirely, creating an economic incentive for Stephens to retain advisory assets in cash in the Bank Sweep Program. Your Financial Consultant does not receive a portion of the fee paid to Stephens by the Banks. m) The Stephens Investment Banking department may introduce its clients, prospective clients, or affiliates thereof, to Stephens Financial Consultants. This introduction is done in Stephens’s capacity as a registered broker-dealer, and not as a registered investment adviser. If the introduction results in a new account relationship, then for a period of years a portion of the net revenue from such account is allocated to the Investment Banking department as a referral fee. Such revenue is considered, along with other factors, in the determination of compensation for the introducing investment banker(s). This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. ADV Part 2A March 31, 2025 42  For more detailed information regarding PCG programs, SCM programs, SMID, SC, and the SFIM Program, please see the ADV Part 2A Appendix 1 for each program. The Part 2A for the Equity Research Advisory Program is also available. Who to Contact We are pleased to have an opportunity to serve as your investment adviser. If you have any questions about the information contained in this brochure or about any aspect of the services we provide, please do not hesitate to call Stephens at (877-891-0095). Clients often receive this information by electronic delivery. The Stephens ADV and additional brochures are now available at www.stephens.com/investment- disclosures/. To access your FC or IAR’s SEC Advisor Biography, go to www.stephens.com , use the search bar in the top right corner of the home page and search by your FC or IAR’s name. SEC Advisor Biographies are also available in the "Our People" section and are there for your review. ADV Part 2A March 31, 2025 43 

SEC File No: 801-15510 Stephens Inc. Equity Research Services Program 111 Center Street Little Rock, Arkansas 72201-4430 877-891-0095 Website: www.stephens.com Form ADV: Part 2A March 31, 2025 Uniform Application for Investment Advisor Registration This brochure provides information about the qualifications and business practices of Stephens Inc. related to the Stephens Equity Research Services Program. If you have any questions about the contents of this brochure, please contact us at 877-891-0095 or www.stephens.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. information about Stephens Inc. also is available on the SEC’s website at Additional www.adviserinfo.sec.gov. Stephens Inc. is a registered investment adviser with the United States Securities and Exchange Commission. Registration does not imply a certain level of skill or training. ADV Part 2A – Equity Research Services March 31, 2025 1  Item 2 Material Changes This section identifies and discusses material changes to the Equity Research Services Form ADV, Part 2A (“Brochure”) since the prior annual updating amendment to the Brochure, which was filed on March 28, 2024. For more details, please see the items in this ADV Brochure referred to in the summary below. Item 14 was updated to disclose: (i) payments employees of Stephens Inc. and its affiliates can receive for referring prospective clients seeking investment advisory services, and (ii) payments Financial Consultants and Investment Advisor Representatives are eligible to receive for making referrals to Stephens Inc.’s Investment Banking division. ADV Part 2A – Equity Research Services March 31, 2025 2  Item 3 Table of Contents FORM ADV: PART 2A .................................................................................................................................................. 1 ITEM 2 MATERIAL CHANGES ................................................................................................................................. 2 ITEM 3 TABLE OF CONTENTS ................................................................................................................................. 3 ITEM 4 ADVISORY BUSINESS .................................................................................................................................. 4 A. ADVISORY FIRM AND PRINCIPAL OWNERS ............................................................................................................. 4 B. THE TYPES OF INVESTMENT ADVISORY SERVICES WE PROVIDE ............................................................................ 4 C. ADVISORY SERVICES ............................................................................................................................................... 4 D .WRAP FEE PROGRAMS ............................................................................................................................................ 5 E. ASSETS UNDER MANAGEMENT ............................................................................................................................... 5 ITEM 5 FEES AND COMPENSATION ...................................................................................................................... 5 A. OVERVIEW OF FEE ARRANGEMENTS EQUITY RESEARCH REPORTS ...................................................................... 5 B. PAYMENT AND COLLECTION OF FEES ..................................................................................................................... 6 C. OTHER TYPES OF FEES AND EXPENSES CLIENTS MAY PAY ................................................................................... 6 D. PRE-PAID ADVISORY FEES...................................................................................................................................... 6 CONDUCTING BUSINESS THROUGH STEPHENS ............................................................................................ 6 LIMITATIONS ON STEPHENS’ ROLE AND RESEARCH SERVICES ............................................................. 6 ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................. 7 ITEM 7 TYPES OF CLIENTS .................................................................................................................................... 7 ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .............................. 7 A. METHODS OF ANALYSIS .......................................................................................................................................... 7 B. STRATEGIES ............................................................................................................................................................ 8 C. RISK OF LOSS .......................................................................................................................................................... 8 MATERIAL RISKS ................................................................................................................................................... 8 ITEM 9 DISCIPLINARY INFORMATION .............................................................................................................. 10 ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................. 11 A. OTHER BUSINESS ACTIVITIES ............................................................................................................................... 11 B. STEPHENS INDUSTRY AFFILIATIONS ..................................................................................................................... 11 C. AFFILIATIONS ....................................................................................................................................................... 11 D. ARRANGEMENTS WITH RELATED INVESTMENT ADVISER OR INVESTMENT COMPANIES ..................................... 12 ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ............................................................................................................................................... 13 A. INVESTMENT ADVISORY CODE OF ETHICS ........................................................................................................... 13 B. CONFLICTS OF INTEREST OWNERSHIP ................................................................................................................. 13 C. STEPHENS PERSONAL TRADING ............................................................................................................................ 14 D. CONFLICT OF INTEREST WITH PERSONAL TRADING AND CLIENT TRADES .............................................................. 15 ITEM 12 BROKERAGE PRACTICES ...................................................................................................................... 15 BROKER-DEALERS SELECTION OR RECOMMENDATIONS ........................................................................................... 15 RESEARCH AND OTHER SOFT DOLLAR BENEFITS ...................................................................................................... 16 ITEM 13 REVIEW OF ACCOUNTS.......................................................................................................................... 16 ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION ..................................................................... 16 ITEM 15 CUSTODY .................................................................................................................................................... 17 ITEM 16 INVESTMENT DISCRETION ................................................................................................................... 17 INVESTMENT OR BROKERAGE DISCRETION ............................................................................................................... 17 ITEM 17 VOTING CLIENT SECURITIES............................................................................................................... 17 POLICIES AND PROCEDURES FOR PROXY VOTING ..................................................................................................... 17 ITEM 18 FINANCIAL INFORMATION ................................................................................................................... 17 OTHER POTENTIAL CONFLICTS OF INTEREST .............................................................................................. 17 WHO TO CONTACT................................................................................................................................................... 19 ADV Part 2A – Equity Research Services March 31, 2025 3  Item 4 Advisory Business This Brochure relates to the Stephens Equity Research Services Program offered by Stephens Inc. ("Stephens") to institutional clients of Stephens. Stephens provides a comprehensive array of financial services to its clients through various broker-dealer services and investment advisory programs. A. Advisory Firm and Principal Owners Stephens is an Arkansas corporation which registered with the United States Securities and Exchange Commission (“SEC”) as a broker-dealer in September 1946. Stephens registered as an investment advisor with the SEC on September 19, 1980 and began providing investment advisory services at that time. Who Are Our Owners Our Firm is owned by SI Holdings Inc. which is a privately held company owned by the Warren A. Stephens Trust which is controlled by Warren A. Stephens. Stephens is owned by the following individuals and entities in the percentages noted: 100%, Trustee of 100%, which owns 100%, which owns 100%, which owns Warren A. Stephens Warren A Stephens Revocable Trust #Two Stephens Financial Services LLC SI Holdings Inc. Stephens Inc. B. The Types of Investment Advisory Services We Provide Stephens provides investment advisory services to individuals, pension plans, foundations, corporations, other business entities, and research relationships with institutional clients and other types of clients. Our investment focus is on US equity securities that may be purchased for client accounts depending on the investment objective of the client. C. Advisory Services In the Stephens Equity Research Services Program, we offer research reports and other products and services (“Research Services”) provided by Stephens’ Research Department to a wide variety of Stephens clients. Under certain circumstances, we provide these Research Services for a fee to certain institutions upon their request. We do not offer Research Services for a fee to clients who are individuals. Research Services includes, but is not limited to, the following types of research products and services: • Published research reports produced by research analysts; • Other research-related communications from research analysts relating to published research reports produced by research analysts; • Access to company management in connection with field trips, non-deal roadshows, conferences, investor meetings, and other firm events; and • Access to research analysts in connection with research conferences, calls with clients, and client meetings. Our Research Analysts cover in excess of 400 stocks focusing on more than 30 sub-sectors within five broad industries: • Consumer • Financial Services ADV Part 2A – Equity Research Services March 31, 2025 4  Industrials and Energy • Healthcare • • Technology, Media and Telecommunications Research Services does not include any services or communications provided by Stephens’ Institutional Equity sales personnel. The delivery of Research Services does not include trade execution, trading or brokerage services provided to clients. Under the Stephens Equity Research Services Program, an advisory relationship with our clients is strictly limited to the provision of Research Services, and any trades, transactions or orders that may be executed, routed, or otherwise processed through us on behalf of clients will be handled by us solely in our capacity as a broker-dealer. The Stephens Equity Research Services Program does not include the provision of any investment advice with respect to our clients’ individual investment portfolios or the management of assets. The provision of Research Services under the Stephens Equity Research Services Program will remain in effect until terminated by either party. The Stephens Equity Research Services Program is offered only to institutional clients. In addition, however, Stephens offers a wide variety of investment advisory services through our other advisory programs. More information about these programs and services is contained in the applicable Stephens brochure and is available through the SEC’s website. For more detailed information regarding Stephens Private Client Group Programs, Stephens Capital Management Programs, and the Stephens Fixed Income Management Programs, please see the ADV Part 2A Appendix 1 for each program, available at https://www.stephens.com/investment-disclosures/. Research Services does not include any evaluation or recommendation by Stephens of the investment guidelines or security selection for our clients’ investment portfolios or the management of assets. Research Services are solely impersonal investment advice. D .Wrap Fee Programs We do not make Research Services available through wrap fee programs. E. Assets Under Management The Stephens Equity Research Services Program does not encompass the management of client assets. As of December 31, 2024, in other advisory programs offered by the firm, Stephens managed and/or advised the following amount of client assets: $ 11,841,493,552 $ 3,771,290,459 $ 8,842,249,582 $ 24,455,033,593 Discretionary Non-Discretionary Consulting Total Assets Under Advisement Item 5 Fees and Compensation A. Overview of Fee Arrangements Equity Research Reports Fees for Research Services are negotiable and vary from client to client. Fees are generally paid periodically, typically in arrears, and may be paid on a schedule negotiated by the parties. ADV Part 2A – Equity Research Services March 31, 2025 5  Depending on the client, Stephens Research’s compensation may be determined using a ‘broker vote’ process or by analyzing data comprised of the research-related products and services provided by Stephens. Ultimately, Stephens Research receives remuneration for investment research and research-related services based on its perceived value as determined by the client. Actual remuneration is determined by the client, is typically received in arrears, and is paid by the institutional investor’s broker(s) at intervals they and/or their broker determine. B. Payment and Collection of Fees Stephens Research Services does not manage client assets and, therefore, does not deduct fees from clients’ assets. Instead, Stephens Research provides an invoice upon request or when otherwise deemed necessary. Payments, payment terms, and payment schedules are negotiable and, in some cases, governed by contract between a client and Stephens. C. Other Types of Fees and Expenses Clients May Pay Stephens Research Services offers only investment research and research-related services as part of our advisory business. Should our clients decide to use or purchase other products or services, certain of our employees will receive fees and compensation for these products and services. Such fees and compensation may include commissions, spreads, and markups, or markdowns. In addition to fees for Research Services, if we are required to collect or pay any sales, gross receipts, excise or use taxes that are levied on us for providing Research Services, then our clients will be obligated to pay or reimburse us for such taxes. D. Pre-Paid Advisory Fees If, in accordance with contractual terms, the institutional client terminates their contract prior to the end of the billing period, we may refund any unearned fees on a pro rata basis after the termination of the contract. CONDUCTING BUSINESS THROUGH STEPHENS You are neither required to act on any of the research information provided through Research Services, nor are you required to transact business with us if you choose to utilize any information or implement any strategies, recommendations or other ideas obtained in connection with Research Services. Research Services are completed upon the delivery thereof. If you choose to implement any of the investment recommendations or strategies made in Research Services through Stephens, we will be acting solely as a broker-dealer, not as an investment adviser, unless otherwise agreed to in writing. In executing transactions in accordance with your instructions, we, acting as a broker- dealer, may act as agent or as principal for our own account. LIMITATIONS ON STEPHENS’ ROLE AND RESEARCH SERVICES Stephens is dually registered as a broker-dealer and an investment adviser and offers both brokerage and investment advisory services. To the extent that we may be deemed to be acting as an investment adviser in connection with the Stephens Equity Research Services Program, our relationship to you pursuant to such program is strictly limited to the provision of Research Services and does not extend to any brokerage or other investment advisory services. If you desire to engage us for additional services, such as brokerage or other investment advisory services, you should carefully consider the differences among these types of services and must enter into a separate agreement with Stephens for such services. Any such arrangement will be separate and apart from ADV Part 2A – Equity Research Services March 31, 2025 6  any relationship created through our provision of Research Services pursuant to the Stephens Equity Research Services Program. We are also a broker-dealer and offer brokerage services to clients, including trade execution and custody through our clearing firm, Pershing LLC (“Pershing”). There are important differences between brokerage and investment advisory services, including the type of advice and assistance provided, the fees charged, and the rights and obligations of the parties. Brokerage services are regulated under different laws and rules than advisory services. Among our many obligations as a broker-dealer, we will execute transactions upon your instruction in the best market we can ascertain, deal fairly with you, and make recommendations that are suitable in light of your stated risk tolerance, financial situation and needs, liquidity needs, investment experience, investment time horizon, and investment objectives. As an investment adviser, we must act solely in your best interest, provide certain specific disclosures, and generally act in accordance with the standards of a fiduciary as that term is interpreted under applicable law. It is important for you to understand these differences, particularly when determining which services you might select. You should carefully read all applicable agreements and disclosure for any services you are considering. Item 6 Performance-Based Fees and Side-By-Side Management We do not have performance-based fee arrangements with any qualified client pursuant to Rule 205-3 under the Investment Advisers Act of 1940, as amended, in the Equity Research Services Program. Item 7 Types of Clients Stephens Equity Research Services provides investment research services to institutional clients only. Examples of institutional clients that we service are traditional long-only large fund management firms, family offices, investment management companies and hedge funds. The type of clients to whom we generally provide Research Services to are financial institutions, many of whom are registered and governed by a regulatory body. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss The investment research which forms the foundation of our Research Services covers a broad range of securities and may be based on the combination and use of multiple different forms of analysis (i.e., fundamental, quantitative, technical, strategic, macro, etc.). Research Services does not include strategic investment advice related to asset allocation at a macro level or overall portfolio composition. Our research analysts perform analysis based on publicly available market, industry, and company data. Research analysts may also meet or speak with management and third parties to gather information and data for the provision of Research Services. A. Methods of Analysis Stephens utilizes numerous sources and inputs for our research reports, including due diligence with management teams, private-company channel checks, industry experts, industry and/or website data, company filings, industry publications, etc. Stephens makes each investment judgment in a “bottom up” fundamental manner based on a myriad of industry and company specific variables, and this analysis generally results in written research reports that can range from only a few lines on minor developments to in-depth industry reports covering multiple companies that are 100+ pages long and supported by in-depth, three-statement financial models that include forward estimates with scenario analyses around critical model drivers. Our investment rating system for securities recommendations is Overweight, Equal-Weight or Underweight using a 12- month time horizon, and analysts can add a Volatile designation to the above ratings when they believe it is warranted. ADV Part 2A – Equity Research Services March 31, 2025 7  B. Strategies The Stephens Equity Research Services Program does not provide bespoke research reports tailored to the particular needs of any individual or group, nor does it provide investment advice to individuals regarding their personal investment strategies. In accordance with applicable rules and regulations, we note that our stock ratings of “Overweight,” “Equal-Weight,” and “Underweight” most closely correspond with the more traditional ratings of “Buy,” “Hold,” and “Sell,” respectively. Our company ratings are based on a combination of our expectations regarding: 1) relative group/sector performance (vs. other equity stocks within the group/sector), 2) relative market performance (vs. S&P 500 and other broader market indices), and 3) absolute performance (whether the group and/or individual stocks will advance or decline). The methods used to determine ratings and price targets are generally based on our near-term and long-term views on key risks and catalysts, investor sentiment, key financial estimates (e.g., revenue, earnings, EBITDA, FCF, etc.), historical and/or relative valuation multiples, and/or discounted cash flow methodology. There is no intention to “balance” the number of Overweight or Underweight ratings at the analyst or firm level. C. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. We believe that an investor’s decision to buy or sell a security should always take into account, among other things, the investor’s particular investment objectives and experience, risk tolerance, and financial circumstances. In providing Research Services, we may also rely on third-party sources for information that we believe to be reliable, but in no way do we guarantee the quality, accuracy and/or completeness of such third-party information or Research Services or any other information or data related thereto that you or any other authorized user or other person or entity otherwise obtain or derive in connection with the use of Research Services. We make no express or implied warranties. If you choose to implement any of the investment recommendations set forth in our investment research, you will be subject to investment risk and may lose money. You should further understand that all investments involve risk, performance of any kind can never be predicted or guaranteed, and the value of your portfolios will fluctuate due to market conditions and other factors. MATERIAL RISKS The following is a summary of the material risks associated with the use of Research Services: • • Information provided in connection with Research Services is for general use only. Neither the information nor any opinion expressed constitutes an offer, or an invitation to make an offer, to buy or sell any securities or other investment or any options, futures, or other derivatives related to securities or investments. Research Services does not provide personalized investment advice, and the information provided by Research Services does not take into account the specific investment objectives, financial situation, or the particular needs of any specific person. Investments involve numerous risks, including, among others, market risk, counterparty-default risk, and liquidity risk. No security is suitable for all investors. In some cases, securities may be difficult to value or sell, and reliable information about the value or risks related to the security or financial instrument may be difficult to obtain. Investors should note that income from securities and other financial instruments, if any, may fluctuate, that price or value of such securities and instruments may rise or fall, and in some cases, investors may lose ADV Part 2A – Equity Research Services March 31, 2025 8  their entire principal investment. Past performance is not necessarily a guide to future performance. Levels and basis for taxation may change. • We may change our views and opinions expressed in Research Services and our views and opinions are subject to change without notice. We have exclusive authority to determine the Research Service’s coverage of companies, markets and other subjects and topics of Research Services, and we can terminate, limit or suspend coverage of any such company, market, subject or topic for any or no reason. We may limit, suspend or terminate the Research Services in connection with regulatory restrictions or our policies. • We are aware that the implementation of the ideas expressed in the report may depend upon your ability to “short” securities or other financial instruments and that such action may be limited by regulations prohibiting or restricting “short selling” in many jurisdictions. You are urged to seek advice regarding the applicability of such regulations prior to executing any short idea contained in the report. • Foreign currency rates of exchange may adversely affect the value, price or income of any security or financial instrument mentioned in the report. Investors in such securities and instruments, including ADRs, effectively assume currency risk. • We or our affiliates may, at any time, hold a trading position (long or short) in the securities and financial instruments discussed in research reports. • We, through business units other than Research, may have issued and may in the future, issue trading ideas or issue market commentary that are inconsistent with, and reach different conclusions from, the information presented in the Research Services report. Such ideas reflect the different time frames, assumptions, views and analytical methods of the persons who prepared them, and we are under no obligation to ensure that such other trading ideas are brought to the attention of any recipient of such research report. • Research reports are based on public information that may not reflect information known to professionals in other areas of our business, including investment banking personnel. • Research reports may contain discussions and/or investment opinions relating to securities, financial instruments and/or issuers that are no longer current. Company fundamentals and earnings may be mentioned occasionally but should not be construed as a recommendation to buy, sell, or hold the company’s stock. Predictions, forecasts, or estimates for any and all markets should not be construed as recommendations to buy, sell, or hold any security including mutual funds, futures contracts, and exchange traded funds, or any similar instruments. ‐‐ Other Disclosures Certain investment programs offered by Stephens to clients sometimes engage in purchases or sales of securities that are consistent or inconsistent with research analyst recommendations. These programs are managed on a discretionary basis or provide investment recommendations by program managers in the exercise of their independent judgment and analysis. Stephens’ directors, officers and employees are allowed to participate in these programs subject to established account minimums and applicable compliance restrictions. The report is prepared solely for informative purposes as of its stated date and is not a solicitation or an offer to buy or sell any security. It does not purport to be a complete description of the securities, markets or developments referred to in the material. Information included in the report was obtained from internal and external sources which we consider reliable, but we have not independently verified such information and do not guarantee that it is accurate or complete. Such information is believed to be accurate on the date of issuance of the report, and all expressions of opinion apply on the date of issuance of the report. No subsequent publication or distribution of ADV Part 2A – Equity Research Services March 31, 2025 9  this report shall mean or imply that any such information or opinion remains current at any time after the stated date of the report. Additional risk factors as identified by the Subject Company and filed with the SEC may be found on EDGAR at www.sec.gov. Prices, yields, and availability are subject to change with the market. It is not intended, nor should be construed, as legal, accounting, regulatory or tax advice. Any discussion of tax attributes is provided for informational purposes only, and each investor should consult his/her/its own tax advisors regarding any and all tax implications or tax consequences of any investment in securities discussed in this report. From time to time, our published research reports may include discussions about potential short- term trading opportunities or market movements that may or may not be consistent with Stephens’ long-term investment thesis, rating, or price target. We provide supplemental news and analysis in Quick Take blogs available to clients on our website and sent to clients via e-mail. If applicable, when reading research on Business Development Companies, you should carefully consider the investment objectives, charges, risks, fees and expenses of the investment company before investing. The prospectus, and, if available, the summary prospectus, contain this and other information about the investment company. You can obtain a current prospectus, and, if available, a summary prospectus, by contacting your financial consultant. Please read the prospectus, and, if available, the summary prospectus, carefully before investing as it contains information about the previous referenced factors and other important information. Also, please note other reports filed with the SEC by the relevant investment company on EDGAR at www.sec.gov. The report may include one or more links to external or third-party websites. Stephens has not independently verified the information contained on such websites and can provide no assurance as to the reliability of such information, and there can be no assurance that any opinions expressed therein agree with or represent the opinions of Stephens or its management. Item 9 Disciplinary Information In May of 2016, prior to the Equity Research services becoming an investment advisory service, Stephens consented to certain FINRA sanctions and to the entry of findings that it did not adequately supervise the content and dissemination of firm-wide “Flash” emails through which its research analyst alerted other firm personnel to news and insights concerning companies and industries covered by Stephens’ Research Department. With those findings, Stephens accepted a fine of $900,000.00 and within 60 days of the date of the notice of acceptance of the AWC certified to FINRA that it had ceased distributing “Flash” emails. Within 90 days of the date of notice of acceptance, Stephens submitted to FINRA a written plan of how it would conduct a comprehensive review of the adequacy and implementation of policies and procedures and training in the Research area. Stephens voluntarily participated in the SEC’s Share Class Selection Disclosure Initiative, and on March 11, 2019, the SEC entered a Cease and Desist Order against Stephens in which Stephens neither admitted nor denied the allegations of the SEC’s Order. The Order alleged that Stephens did not fully disclose conflicts of interest related to the selection of mutual fund share classes for its advisory clients, and that Stephens purchased, recommended, or held mutual fund share classes for client accounts which paid Stephens 12b-1 fees when less expensive share classes of the same funds were available which did not pay Stephens these 12b-1 fees. The Order directed Stephens to Cease and Desist from committing or causing any violations and any future violations of Sections 206(2) and 207 of the Investment Advisers Act of 1940 and ordered that Stephens be censured and pay disgorgement and prejudgment interest to advisory clients who held these more expensive mutual funds share classes in their advisory accounts. (IA Release No. 40-5196). ADV Part 2A – Equity Research Services March 31, 2025 10  In its capacity as a broker-dealer, Stephens has been subject to legal or disciplinary events in the ordinary course of its business, such as regulatory sanctions relating to compliance with broker- dealer trade reporting requirements and other regulatory actions. Item 10 Other Financial Industry Activities and Affiliations A. Other Business Activities In addition to Investment Advisory services, Stephens is registered with the SEC as a broker-dealer. Stephens provides services as appropriate and contemplated under these registrations. B. Stephens Industry Affiliations Stephens is a full-service broker-dealer and investment bank. In addition to being registered with the SEC, Stephens is a member of the Financial Industry Regulatory Authority (“FINRA”), the New York Stock Exchange, Inc. (“NYSE”), the NYSE American LLC (“NYSE-AMEX”), the Municipal Securities Rulemaking Board (“MSRB”), the Investors’ Exchange LLC (“IEX”) and the Securities Investor Protection Corporation (“SIPC”). Affiliates of Stephens are also separately engaged in financial services businesses, including merchant banking, insurance, and investment advisory businesses. C. Affiliations 1. Affiliated Funds Stephens may from time to time engage in transactions on behalf of clients with Hotchkis & Wiley Capital Management LLC (“H&W”) or with mutual funds advised by H&W. H&W is an investment adviser registered with the SEC in which entities under common control with Stephens hold an ownership interest. H&W provides investment advisory services to corporate, pension, public, endowment, foundation, mutual fund and other clients, and H&W also advises its own family of mutual funds. Stephen may also from time to time engage in transactions on behalf of clients with Stephens Investment Management Group LLC (“SIMG”). SIMG is an investment adviser registered with the SEC in which affiliates of Stephens hold the entire ownership of voting securities. SIMG provides investment advisory services for separate account clients and for mutual funds known as the American Beacon Stephens Funds® or other funds which may be added from time to time. Additionally, SIMG serves as one of the investment advisors to the following multi-manager mutual funds using its SMID Select Growth Strategy or Small Cap Growth Strategy: • Vanguard Explorer™ Fund; • Bridge Builder Small/Mid Cap Growth Fund; and • First Trust Multi-Manager Small Cap Opportunities ETF (“MMSC”). H&W advised mutual funds and SIMG advised mutual funds are offered through Stephens’ broker- dealer services and/or investment advisory services as part of an investment program. Clients that invest in H&W advised mutual funds or in SIMG advised mutual funds bear a proportionate share of the fees and expenses of those funds including the management fees or other fees paid to H&W or SIMG. These fees and expenses include commissions or fees, if any, paid to Stephens in connection with portfolio transactions. Please refer to each mutual fund’s prospectus for a full discussion of the fees and expenses of each mutual fund. 2. Stephens Sponsored Wrap Fee Program ADV Part 2A – Equity Research Services March 31, 2025 11  Stephens sponsors the Stephens Small-Mid Cap Core (“SMID Core”) Growth Program which is a wrap fee program sub-advised by SIMG that follows its SMID Core Growth Model. FCs or IARs are not financially incentivized to place clients in the SMID Core Growth Program versus any other wrap program or platform available at Stephens. However, a portion of the SMID Core account fees, generally representing twenty to fifty percent (20%-50%) of SMID Core fees, will be paid to SIMG for its portfolio management services, pursuant to a sub-advisory agreement between Stephens and SIMG. SIMG and Stephens share common ownership which benefits from the compensation generated to SIMG as the result of a client investing in the SMID Core Growth Program. Depending on the level of trading, the value of the account, and types of securities purchased or sold, clients may be able to obtain transaction execution at a higher or lower cost if purchased separately at Stephens or SIMG than through this wrap fee program. 3. Affiliated Investment Management Activities Certain investment strategies offered by SIMG have been selected for inclusion in the Private Client Group’s (“PCG”) Managed Assets Program (“MAP”). Sub-Advisors and strategies may only participate in MAP if they have been approved by the MAP Investment Committee. The MAP Investment Committee employs a process for evaluating investment managers that includes both qualitative and quantitative factors. SIMG strategies participating in MAP are subject to the same due diligence and evaluation processes as sub-advisors or strategies that have no affiliation with Stephens. FCs are not financially incentivized to favor selecting SIMG strategies over non- affiliated sub-advisors or strategies. However, selection of an SIMG strategy in MAP generates compensation to SIMG, which shares common ownership with Stephens. 4. Other Affiliations Certain entities affiliated with Stephens or under common control with Stephens hold an ownership interest in Alex Brown Realty, LLC., a registered investment adviser. From time to time, Stephens offers to its clients securities sponsored by Alex Brown Realty, LLC. Stephens sometimes refers clients to Stephens Insurance, LLC, an affiliated insurance agency under common control with Stephens, for advice pertaining to products that are provided through Stephens Insurance, LLC, and Financial Consultants and Investment Advisor Representatives may be eligible, subject to regulatory and legal requirements, to receive referral fees for insurance business referred. Stephens Insurance, LLC, may refer prospects seeking investment advisory services to Stephens. If the referral results in a new account relationship, then a portion of the net revenue from such account may be paid to Stephens as a referral fee. This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. For further information that pertains to related persons of Stephens, please refer to “Other Potential Conflicts of Interest” following Item 18 below. D. Arrangements with Related Investment Adviser or Investment Companies From time to time, Stephens and its Financial Consultants and/or Investment Advisory Representatives may recommend that clients invest in investment products that are affiliated with Stephens. Such arrangements are described in greater detail in Item 10.C above. Such a recommendation of affiliated investment products creates a potential conflict of interest because Stephens, its affiliates, and their beneficial owners may receive higher aggregate compensation than if clients invest in unaffiliated investment products. Stephens addresses this potential conflict through disclosure, including in this Brochure. Additionally, when acting as fiduciaries, Stephens Financial Consultants and Investment Advisor Representatives are required to recommend affiliated investment products only when they determine it is in the client’s best interest to do so. ADV Part 2A – Equity Research Services March 31, 2025 12  Financial Consultants or Investment Advisor Representatives are not financially incentivized to recommend Stephens-affiliated products over any other investment product available at Stephens. In no case are you under any obligation to purchase any products or services sold by us or our affiliates. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Investment Advisory Code of Ethics Stephens has adopted an Investment Advisory Code of Ethics (“Code”), which defines the requirements and expectations for the business conduct of all of its Investment Advisory employees, including equity research employees of Stephens. Our Code also addresses receipt and/or permissible use of material non-public information and other confidential information our Access Persons as defined in Rule 204A-1(e)(1) of the Investment Advisors Act may be exposed and/or have access to. The Code is provided upon hire and at least annually thereafter, and at each time, the Access Person must certify in writing that she or he has received, read, and understands the Code and that they agree to or have complied with its contents. Furthermore, all Stephens’ employees are expected to adhere to Stephens’ Mission and Values Statement and Code of Professional Conduct. The fundamental position of Stephens is that all aspects of its business are to be conducted in an ethical and legal manner in accordance with federal law and the laws of all states where the investment advisory divisions do business. In accordance with that position, general principles apply: 1. The interests of Stephens’ clients are our first consideration. Any personal securities transaction, which would be detrimental or potentially detrimental to any client account, and any personal securities transaction, which is designed to profit by the market effect of any client account, must be avoided. 2. All personal securities transactions should be conducted in such a manner as to be consistent with the Code and to avoid actual or potential conflicts of interest or abuse of a Stephens’ employee’s knowledge of customer information or customer transactions. 3. Investment adviser personnel should not take inappropriate advantage of their positions. Information concerning the identity of security holdings and financial circumstances of clients is confidential. 4. Independence in the investment decision-making process is paramount. Accordingly, there are certain standards of conduct that Stephens investment advisory employees follow to reduce potential conflicts with the interests of our clients. Stephens will provide a copy of the Code to any client or prospective client upon request. B. Conflicts of Interest Ownership Interest in Client Transactions The Stephens Equity Research Services Program does not include the management of client assets or the trading of securities for clients. Through various broker-dealer services, Stephens acts as agent for the client in securities transactions, and Stephens acts as dealer for clients in principal transactions. ADV Part 2A – Equity Research Services March 31, 2025 13  When acting as investment adviser, Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing the capacity in which it is acting. As a practical matter, the above requirements may impose delays on the time at which principal transactions may be affected for advisory accounts, and thereby may impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. Transactions in which Stephens acts as a principal will only be affected for clients subject to the client’s written consent to such transaction indicating the quantity and price of the securities being purchased or sold. If Stephens is acting as a market-maker or otherwise as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a customer. Stephens does not engage in agency cross transactions (transactions where we or our affiliate executes a transaction while acting as a broker for both our client and the other party in the transaction). As a broker-dealer and investment adviser providing a comprehensive array of financial services to our clients through multiple business lines, we and our employees may have interests unrelated to Research clients which may give rise to potential conflicts of interest, including those discussed below. Stephens’ personnel can suggest or recommend that Research Services clients also use other Stephens’ products or services or products or services of an affiliate. Where Stephens or our affiliate’s services are used or products are purchased by clients, Stephens and our affiliates will receive fees and compensation. Sales representatives may, as permitted by applicable law, receive compensation, the amount of which may vary in connection with these products and services. Compensation received in connection with clients’ purchase or sale of stocks, bonds, mutual funds, other securities or insurance products through us or our affiliates may include commissions, spreads, markups and markdowns, and distribution or other fees. We will also benefit from the possession or use of free credit balances in client accounts, subject to the restrictions imposed by Rule 15c3-3 under the Exchange Act. As a broker-dealer effecting transactions on behalf of clients, including those clients who receive Research Services, we or an affiliate may act as agent or as principal for our own account, as permitted by applicable law. Similarly, we or an affiliate may, in transactions involving such clients’ securities, act as agent while also representing another client on the other side of the transaction. In addition, we or our affiliates may have a position in, or enter purchase or sale orders for, securities recommended to clients in the normal course of our business as a broker-dealer. We and/or our affiliates may profit from these positions or transactions in securities. We address these conflicts through disclosure in this Brochure. In addition, we have established a variety of restrictions, procedures and disclosures designed to address potential conflicts of interest - both those arising between and among client accounts as well as between client accounts and our business. For example, our personnel also are subject to personal trading restrictions as detailed in our policies and procedures and Code. These policies and procedures and the Code require our Access Persons to pre-approve certain securities transactions, disclose their investment accounts, and provide or cause Stephens to receive annual holdings reports and quarterly transaction reports. C. Stephens Personal Trading Our Code is designed to ensure that Access Persons and their immediate family’s personal trading activities does not interfere with our clients’ interests. Immediate family for purposes of this filing ADV Part 2A – Equity Research Services March 31, 2025 14  is defined by FINRA Rule 3241(c). While our Access Persons (and their immediate family) may maintain personal investment accounts, they are subject to certain restrictions. Stephens’ Research Department employees are subject to a number of limitations on personal trading, including, but not limited to the following: 1. Research personnel are prohibited from trading in stocks they cover or intend to cover for Stephens. 2. Research personnel are prohibited from trading in stocks covered by another Stephens’ analyst in the same sector(s), as set forth on the coverage list (e.g., bank analysts are prohibited from buying any bank stock covered Stephens research). 3. Research personnel are prohibited from trading in stocks covered by another Stephens’ analyst in a different sector if both (i) the stocks are driven by the same industry fundamentals as the stocks they cover, and (ii) the analysts co-author research reports. 4. Research personnel should avoid trading in stocks covered by another Stephens’ analyst in a different sector if such stocks are driven by the same industry fundamentals as the stocks they cover. All employees are required to maintain their personal accounts and accounts in which they have a beneficial interest at Stephens unless the account has been specifically made exempt in writing from this requirement. Stephens’ employees are required to provide copies of all their trade confirmations and brokerage account statements to Stephens’ Compliance Department in order to permit the monitoring of compliance with personal trading policies and restrictions. Additionally, employees are required to report all personal securities transactions no less than quarterly. Stephens’ Code requires employees to report violations of the Code to Stephens Chief Compliance Officer. D. Conflict of Interest with Personal Trading and Client Trades To minimize potential conflicts of interest, investment advisory personnel who determine or approve what recommendations will be made for client accounts will not participate in Stephens’ trading activities and will not know what trading strategies are employed for its proprietary accounts. See Item 11.C for more detail Equity Research employee trading policies. It should be noted, however, that Stephens allows purchases to be made in the marketplace by its employees of securities owned by any client account, provided that such purchases are made in amounts consistent with the normal investment practice of the person involved. Such purchases must be made after the investment advisory accounts managed by such employee (or in the management of which such employee participates) has completed its transactions in such securities. Under certain circumstances, employee transactions may be permitted prior to full completion of investment advisory division’s transactions. Such exceptions require prior approval of the appropriate Preclearance Officer and will only be granted after considering factors such as the time element involved in filling the order, market considerations, etc. Item 12 Brokerage Practices Broker-dealers Selection or Recommendations The Stephens Equity Research Services Program does not select broker-dealers or engage in securities transactions. ADV Part 2A – Equity Research Services March 31, 2025 15  Research and Other Soft Dollar Benefits Stephens does not enter into arrangements with other broker-dealers whereby it receives free research in exchange for the placement of a specified amount of client trades. Item 13 Review of Accounts Supervision and Review Research Services does not provide any personalized investment advice with respect to our clients’ investment portfolios or the management of assets. Accordingly, there are no account reviews of investment accounts. We will make available to our clients research reports and other research products from time to time. Primary responsibility for the supervision of Stephens Research Department employees lies with the applicable Stephens’ Supervisory Principal. The Supervisory Principal’s daily and/or monthly reviews will consist of: analysis of activity in an Stephens Research employee account; electronic communications review; identification of selective dissemination of material information. • • • Supervisory and Compliance procedures for Internal-Use-Only materials; and • The reviewers may refer accounts to the Compliance Department for further analysis if necessary. Oral Communications Stephens Research Department supervisors monitor analyst communications for compliance with Research Department procedures. Trading Stephens’ Research Department employees are subject to a number of limitations on personal trading. See Item 11.C for more detail Equity Research employee trading policies. Supervisors conduct daily reviews of employee and employee-related accounts held at Stephens and other firms to determine whether there is potentially suspicious trading, including, but not limited to, whether trading violates the prohibitions outlined above. Compliance conducts daily review of trading in Research Department employee and employee- related accounts to determine whether the employee’s personal trading is in violation of Stephens’ 15-day holding period for trades in securities of any company covered by Stephens’ research. Item 14 Client Referrals and Other Compensation Neither Stephens nor any of our employees receives any sales awards or other prizes from any non- affiliated outside parties for providing investment advice to our clients. Stephens may enter into referral arrangements with its affiliates or between divisions of the Firm. This includes referrals to Stephens of prospective clients seeking investment advisory services. If the referral results in a new account relationship, then a portion of the net revenue from such account is paid to such entity or division as a referral fee, and such entity or division may pay some portion of the fee to the referring person. This arrangement is disclosed to the client and does not ADV Part 2A – Equity Research Services March 31, 2025 16  result in any additional fees or charges to the client. Such arrangements are conducted in accordance with the Marketing Rule, as applicable, and the Advisers Act generally. Financial Consultants and Investment Advisor Representatives are eligible to receive referral fees for referring eligible clients to the Stephens Investment Banking division. For eligible investment banking referrals, referring parties are eligible to receive compensation as a percentage of net income earned by Investment Banking. Therefore, Financial Consultants and Investment Adviser Representatives are incentivized to refer clients to the Investment Banking division. Any such compensation to the Financial Consultant or Investment Advisor Representative is at the discretion of the Firm. Item 15 Custody The Stephens Equity Research Services Program does not provide custody for advisory clients. Item 16 Investment Discretion Investment or Brokerage Discretion Under the Stephens Equity Research Services Program, we do not provide discretionary portfolio management services for these advisory services. Item 17 Voting Client Securities Policies and Procedures for Proxy Voting Under the Stephens Equity Research Services Program, we do not provide proxy voting services for these advisory services. Item 18 Financial Information Stephens does not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance and, thus, has not included a balance sheet of its most recent fiscal year. Stephens is no aware of any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to our clients. Other Potential Conflicts of Interest Stephens is a diversified financial services company that directly or through affiliates provides a wide variety of investment banking, securities, insurance and other investment-related services to a broad array of customers. These relationships could give rise to potential conflicts of interest. Potential conflicts of interest for the Equity Research Program can include, but are not limited to, the following: • If the research analyst or a member of the research analyst’s household has a financial interest in the debt or equity securities of the Subject Company (including, without limitation, whether it consists of any option, right, warrant, future, long or short position); • If, Stephens or its affiliates beneficially own 1% or more of any class of common equity securities of the Subject Company; • If Stephens or any of its officers own options, rights or warrants to purchase any of the securities of the Subject Company, unless the extent of such ownership is nominal; ADV Part 2A – Equity Research Services March 31, 2025 17  • If the research analyst received compensation that is based upon (among other factors) Stephens’ investment banking revenues; or from the Subject Company in the past 12 months; • If Stephens or its affiliates:  managed or co-managed a public offering of securities for the Subject Company in the   past 12 months; received compensation for Investment Banking Services from the Subject Company in the past 12 months unless such disclosure would reveal material non- public information regarding specific future potential investment banking transactions of the Subject Company; or expects to receive or intends to seek compensation for Investment Banking Services from the Subject Company in the next 3 months unless such disclosure would reveal material non-public information regarding specific future potential investment banking transactions of the Subject Company; • If, as of the end of the month immediately preceding the date of publication of a Research Report (or the end of the second most recent month if the publication date is less than 30 calendar days after the end of the most recent month), or to the extent the research analyst or an employee of the firm with the ability to influence the substance of the Research Report knows:  Stephens received any compensation for products or services other than Investment Banking Services from the Subject Company in the past 12 months; or  The Subject Company currently is, or during the 12-month period preceding the date of distribution of the Research Report was, a client of Stephens. In such cases, the Research Report must disclose whether the types of services provided to the Subject Company were Investment Banking Services, non-investment banking securities- related services, or non-securities services. This disclosure must not be made if such disclosure would reveal material non-public information regarding specific future potential investment banking transactions of the Subject Company; • If, to the extent the research analyst or an employee of the firm with the ability to influence the substance of a Research Report knows or has reason to know, an affiliate of Stephens, received any compensation for products or services other than Investment Banking Services from the Subject Company in the past 12 months. In such cases, the research analyst or employee shall report that knowledge to the Legal Department or Compliance Department. No further Research Reports shall be issued until adequate disclosures are included with the Research Report; • If the research analyst or member of a research analyst’s household serves as an officer, director or advisory board member of the subject company, or if an officer or director of Stephens is a director of a corporation whose security is being recommended; • If Stephens was making a market in the Subject Company’s securities at the time that the research report was published; and • any other actual, material conflict of interest of the research analyst or Stephens of which the research analyst knows or has reason to know at the time of publication of the research report or at the time of the public appearance. The “knows or has reason to know” language is intended to require disclosure of those material conflicts of interest of which the Research Analyst has actual knowledge, as well as those conflicts that should be reasonably discovered in the ordinary course of business. It does not impose a duty on a research analyst to inquire concerning confidential, non-public material information protected by the firm’s Information Barrier procedures. ADV Part 2A – Equity Research Services March 31, 2025 18  For more detailed information regarding Private Client Group Programs, Stephens Capital Management Programs and the SFIM Programs, please see the ADV Part 2A Appendix 1 for each program at https://www.stephens.com/investment-disclosures/. Who to Contact If you have any questions about the information contained in this brochure or about any aspect of the services we provide, please do not hesitate to call Stephens at 877-891-0095. Clients often receive this information by electronic delivery. ADV Part 2A – Equity Research Services March 31, 2025 19 

SEC File No: 801-15510 Stephens Inc. 111 Center Street Little Rock, Arkansas 72201-4430 Stephens Small-Mid Cap Core Growth Program 877-891-0095 Website: www.stephens.com. March 31, 2025 Uniform Application for Investment Advisor Registration This wrap fee program brochure provides information about the qualifications and business practices of Stephens Inc. If you have any questions about the contents of this brochure, please contact us at 877-891-0095 or www.stephens.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Stephens Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. Stephens Inc. is a registered investment adviser with the United States Securities and Exchange Commission. Registration does not imply a certain level of skill or training. ADV Part 2A Appendix 1 March 31, 2025 1  Item 2 Material Changes This is an annual update to the Stephens Small-Mid Cap Core Growth Program wrap fee program brochure. This section identifies and discusses material changes since the last annual update dated March 28, 2024. For more details, please see the item in this brochure referred to in the summary below. Item 9 was updated to disclose: (i) payments employees of Stephens Inc. and it affiliates can receive for referring prospective clients seeking investment advisory services, and (ii) payments Financial Consultants and Investment Adviser Representatives are eligible to receive for making referrals to Stephens Inc.’s Investment Banking division. ADV Part 2A Appendix 1 March 31, 2025 2  Item 3 Table of Contents Stephens Small-Mid Cap Core Growth Program .............................................................................................. 1 Item 2 Material Changes ............................................................................................................................................. 2 Item 3 Table of Contents ............................................................................................................................................. 3 Item 4 Services, Fees and Compensation ................................................................................................................... 4 Stephens Small/Mid Cap Core Growth Program ....................................................................................................... 4 Investment Management Agreement ......................................................................................................................... 5 Management Fee Schedule For Stephens Small-Mid Cap Growth Accounts ............................................................ 5 SMID Core Strategy Offered Through Stephens’ MAP ............................................................................................ 6 Collection of Fees ...................................................................................................................................................... 6 Is a Wrap Fee Arrangement for you? ......................................................................................................................... 6 Account Review ........................................................................................................................................................ 6 Confirmations, Account Statements and Performance Reviews ................................................................................ 7 Comparing Costs ....................................................................................................................................................... 7 Additional Fees .......................................................................................................................................................... 7 Item 5 Account Requirements and Types of Clients .............................................................................................. 11 Conditions for Management .................................................................................................................................... 11 Types of Clients ....................................................................................................................................................... 11 Item 6 Portfolio Manager Selection and Evaluation............................................................................................... 12 Affiliated Advisor .................................................................................................................................................... 12 Performance Calculations ........................................................................................................................................ 12 Conflicts of Interest ................................................................................................................................................. 13 Other Potential Conflicts of Interest ........................................................................................................................ 14 Advisory Services .................................................................................................................................................... 19 Restrictions .............................................................................................................................................................. 19 Wrap Fee Programs ................................................................................................................................................. 19 Performance-Based Fees and Side-By-Side Management ....................................................................................... 19 Methods of Analysis, Investment Strategies and Risk of Loss ................................................................................ 20 Policies and Procedures for Proxy Voting ............................................................................................................... 21 Corporate Actions Or Other Matters ....................................................................................................................... 22 Item 7 Client Information Provided to Portfolio Managers .................................................................................. 22 Item 8 Client Contact with Portfolio Managers ...................................................................................................... 22 Item 9 Additional Information ................................................................................................................................. 23 Disciplinary Information ......................................................................................................................................... 23 Code of Ethics ......................................................................................................................................................... 23 Supervision and Review of Accounts ...................................................................................................................... 24 Client Referrals and Other Compensation ............................................................................................................... 24 Financial Information .............................................................................................................................................. 25 Who to Contact ........................................................................................................................................................ 25 Definitions and Professional Designation Qualifications ....................................................................................... 26 ADV Part 2A Appendix 1 March 31, 2025 3  Item 4 Services, Fees and Compensation Stephens Inc. ("Stephens") is an Arkansas corporation which registered with the Securities and Exchange Commission (“SEC”) as a broker-dealer in September 1946. Stephens registered as an investment advisor with the SEC on September 19, 1980 and began providing investment advisory services at that time. Stephens is a full service broker-dealer and investment bank. In addition to being registered with the SEC, Stephens is a member of the Financial Industry Regulatory Authority (“FINRA”), the New York Stock Exchange, Inc. (“NYSE”), the NYSE American LLC (“NYSE-AMEX”), the Municipal Securities Rulemaking Board (“MSRB”), the Investors’ Exchange LLC (“IEX”) and the Securities Investor Protection Corporation (“SIPC”). Stephens derives greater revenues from its broker-dealer and investment banking activities than it derives from its investment advisor activities. Affiliates of Stephens are also separately engaged in financial services businesses, including merchant banking, insurance and investment advisory businesses. Stephens Small/Mid Cap Core Growth Program Stephens Small-Mid Cap Core Growth Program (“SMID Core”) is an investment advisory wrap program of Stephens. The investment portfolio of SMID Core accounts is managed by Stephens Investment Management Group, LLC (“SIMG”), an affiliate of Stephens. SIMG was organized in July 2005 and is registered with the SEC as an investment advisor. SIMG manages and directs the investment of the assets in each SMID Core program client’s account on a discretionary basis in accordance with its small and mid- cap core growth equity investment style and on the basis of the individual objectives and needs of the client within the criteria established by the SMID Core program. SIMG personnel may also provide services to other clients and to other products or programs. In the SMID Core program, SIMG establishes the investment policy and strategy for the portfolio, selects the securities to be included in the portfolio and makes the day-to-day investment decisions. The goal of SIMG is to seek growth of the equity value of a portfolio of small and mid-cap equity investments for clients, consistent with clients’ investment objectives. SIMG attempts to identify core growth stocks among stocks of companies that have a market capitalization at the time of purchase no larger than the market capitalization of the largest company then included in the Russell 2500TM Growth Index, using a disciplined bottom-up approach, employing financial screening techniques, fundamental research and the portfolio managers’ judgment, with a focus on identifying small- cap companies and mid-cap companies believed to have above-average potential for equity growth. The portfolio benchmark is the Russell 2500TM Growth Index. The Russell 2500™ Growth Index measures the performance of those Russell 2500TM companies with higher price-to-book ratios and higher forecasted growth values. The Russell 2500TM Index is a trademark/service mark of the Frank Russell Company. Russell® is a trademark of the Frank Russell Company. SIMG invests SMID Core assets primarily in long positions in equity securities. However, from time to time SIMG may invest SMID Core assets in other types of securities, including without limitation, short term fixed income securities, exchange-traded funds and other investment company securities, and stock index futures. SIMG generally seeks to fully invest cash balances. Investments made through the SMID Core program are concentrated in investments in equities of small- and mid-cap growth companies and are not diversified across other asset classes. Small- and mid-cap growth strategies may be more volatile and less liquid than other investment strategies. Investing in small- cap and mid-cap issuers involves greater risk than investing in more established companies and investors should only invest a portion of their total portfolio in these securities. ADV Part 2A Appendix 1 March 31, 2025 4  Typically, individual investors are advised not to allocate more than ten to fifteen percent of their overall investment portfolio to a small and mid-cap growth strategy. The SMID Core program portfolio is not managed for tax efficiency. The investment strategy used by SIMG in the SMID Core program is also available to appropriate Stephens clients in the Stephens Managed Assets Program (“MAP”). Investment Management Agreement Entering into an advisory relationship with Stephens for the SMID Core program, involves the execution by client of an Investment Management Agreement (“Advisory Agreement” or “Agreement”) and a general account agreement. The term of the Advisory Agreement is generally for a period of one year beginning on the effective date of the agreement and is automatically renewed for successive additional one-year terms without further action. At the time of entering into the Advisory Agreement, the client will be afforded a right to terminate the Agreement within five (5) business days after entering into the Agreement and receive a full refund of any investment advisory fees paid to Stephens. At any time, either the client or Stephens may terminate the Agreement without penalty, upon fifteen (15) days’ notice given in writing to the other party hereto. If the account is to be liquidated as the result of a termination notice, it is understood that Stephens may take up to five (5) trading days to effect such liquidation following the date the liquidation request was received by Stephens. Proceeds will be payable to client within ten (10) business days of termination. Upon termination of the account and payment of all sums, which may be owed to Stephens in connection with the account, Stephens shall make such disposition of the managed securities or other property of the client held by it as may be directed by the client. The client agrees to pay Stephens’ reasonable fees, costs and expenses incurred for such disposition and for collection, including attorney fees, of any unpaid balances under the Agreement. On June 5, 2019, the SEC issued its interpretation of the Standard of Conduct for Investment Advisers and rescinded certain previously issued no action letters. As a result of these changes, Stephens will not seek to enforce any provision of an investment advisory agreement with a retail investor which discharges Stephens or its agents from liability to the retail investor client. Management Fee Schedule For Stephens Small-Mid Cap Growth Accounts Stephens’ fee for a SMID Core account is based on a percentage of assets under management. The annual fee is one and one half percent (1.5%) of assets under management. Fees are negotiable based on a number of factors including the type and size of the account. A portion of the SMID Core account fees, generally representing twenty to fifty percent (20%-50%) of SMID Core fees, will be paid to SIMG for its portfolio management services, pursuant to a sub-advisory agreement between Stephens and SIMG. Stephens’ SMID Core fees apply to standard accounts and include management, trade execution services, associated accounting reports and investment management reports, all provided by Stephens. This is known as a wrap fee. The wrap fee also encompasses commissions on securities transactions executed for SMID Core accounts through Stephens. The SMID Core wrap fee does not include commissions or fees for securities brokerage or execution services provided by other brokerage firms, all of the costs of which (if any) will be borne by the client and charged to the client’s account. The fee, from the opening of the account (“effective date”) to the end of the then-current calendar quarter, will be obtained by computing the adjusted market value of cash and securities in the portfolio as of the close of business on the last day (subsequent to the effective date) of the current calendar quarter and multiplying the resultant market value by one-fourth of the applicable annual fee rate(s), prorated for the percentage of the current calendar quarter during which the portfolio is under management. ADV Part 2A Appendix 1 March 31, 2025 5  The fee for any subsequent three-month period will be the amount obtained by computing the adjusted market value of cash and securities in the portfolio as of the close of business on the last business day of the three-month period and multiplying the resultant market value by one-fourth of the applicable annual fee rate(s). In the event a client’s account is closed between quarter-ends, fees will be prorated as of the date of termination. The fee will be deducted from the client’s account by Stephens quarterly unless otherwise agreed in writing. Clients will receive a Fee Statement following the deduction of the fee. Each security in the portfolio is generally valued as of the close of business on a business day at its last trading price in its primary trading market on that day. A security for which trading has been halted or in which trading has not occurred will be valued at its last trading price or at its last reported or last available bid price or at a price that Stephens believes more accurately reflects the market value of such security in light of the circumstances surrounding the trading halt or the absence of trading activity, as well as the performance and prospects of the company’s business, to the extent such information is made available to Stephens. SMID Core Strategy Offered Through Stephens’ MAP The SMID Core strategy is available to clients of the Stephens Private Client Group through Stephens MAP. Please see Stephens’ Form ADV Part 2A for more information about the MAP program and its fees. Collection of Fees Stephens is authorized to deduct from your account each quarter the amount of the total quarterly wrap fee as described in the Investment Management Agreement, and the other fees, if any, applicable to your account for such calendar quarter. Stephens will issue quarterly reports to you reflecting the transactions in your account and the performance of the investments. Service fees and other transaction changes, if any, will be applied to the account as incurred. Is a Wrap Fee Arrangement for you? The SMID Core program is a “wrap fee program” in which the client pays a single fee for investment advisory services and related services, which may include executions, custody and clearing charges. The SMID Core program may cost the client more or less than purchasing such services separately depending upon such factors as trading activity, account size and investment adviser minimums for non- wrap accounts. We encourage you to carefully consider your options in establishing or maintaining an advisory fee-based account. As a general matter, a fee-based advisory account approach may be considered appropriate for customers who rely on investment advice or investment management services or who engage in moderate to high levels of trading activity. A fee-based approach can be more economical for customers who engage in active trading, since the price per trade is reduced as the number of trades increases under a fee-based approach. However, fee-based advisory account arrangements may not be appropriate for customers who rely primarily on their own independent resources and judgments for making their investment selections and decisions and do not wish to purchase advisory services. Customers who engage in a lower level of trading activity might prefer a traditional brokerage account with a commission payable on each transaction, particularly if the customer typically does not utilize advisory services for trading decisions, as transaction cost savings might be realized in the context of a traditional pay-per-trade commission structure. Typically, a portion of any revenue that the firm realizes in connection with an advisory account will be included in the calculation of the compensation to be paid by the firm to the Financial Consultant (“FC”) or Investment Advisory Representative (“IAR”); and, therefore, the FC or IAR will experience conflicts of interest similar to those experienced by the firm. Account Review ADV Part 2A Appendix 1 March 31, 2025 6  The IAR assigned to your account is your primary point of contact with Stephens. Your IAR should offer to discuss or meet no less frequently than annually with you as an advisory client. Stephens encourages you to contact your IAR at any time if you have questions or would like to have additional discussions or meetings. If you have experienced any changes regarding your finances, investment objectives or risk tolerance, please contact your IAR to see if any adjustments are necessary to your investment strategy. confirmations each trade in favor of e-delivery Confirmations, Account Statements and Performance Reviews In most cases, Pershing LLC (“Pershing”) is the custodian of your account and provides you with written or electronic confirmation of securities transactions, and account statements at least quarterly. You will also receive a monthly account statement if you have had qualifying activity in your account during the month, which will detail the activity and the positions in your account. If you have not had any qualifying activity during the month and you have positions in your account, you will receive a quarterly account statement, which details the positions in your account. You may waive the receipt of account statements or via after You may also receive mutual fund https://stephensaccess.netxinvestor.com/web/stephens/login. prospectuses, where appropriate. We will provide you periodic reviews of your account. These show how the account investments have performed on an absolute basis. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. Comparing Costs Depending on the level of trading and types of securities purchased or sold in your account, you may be able to obtain transaction execution at a higher or lower cost if purchased separately at Stephens than through this wrap fee program. Additional Fees In an advisory program, you will pay Stephens an asset-based wrap fee for investment advisory and other services provided by Stephens or our clearing firm, Pershing LLC (“Pershing”). These services include custody of securities and trade executions with Stephens or Pershing. The wrap fee does not cover: • • • the costs of investment management fees and other expenses charge by Funds and UITs; “mark-ups”, “mark-downs”, and dealer spreads that Stephens receives when acting as principal in certain transactions where permitted by law; brokerage commissions or other charges resulting in transactions not effected through Stephens with Pershing; account transfer fees; processing fees; or certain other cost or changes may be imposed by third parties. • • • As your introducing broker, Stephens can receive or pay compensation for directing order flow in equity securities. Pershing receives compensation for the direction of order flow in certain equity securities and listed options. The source and nature of the compensation, if any, received in connection with trades will be furnished upon your written request to your FC or IAR. ADV Part 2A Appendix 1 March 31, 2025 7  Stephens Insured Bank Sweep Program The Stephens Insured Bank Sweep Program (“Bank Sweep Program” or “Program”) is available to Stephens’ clients through our fully disclosed clearing broker-dealer, Pershing, and Pershing has appointed IntraFi Network LLC (“IntraFi”) to provide certain services in connection with the Program. In the Bank Sweep Program, each bank participating in the program pays a return based on the amount of funds in your Deposit Account at the bank. The interest rate applicable to your Deposit Accounts is determined by the amount of interest participating banks are willing to pay on the aggregate balance of the deposits minus: (i) the feeds paid to IntraFi, as administrator, (ii) the fees paid to Pershing for its services, and (iii) the fees paid to Stephens. Stephens retains and exercises the right to negotiate its own fee and may reduce or increase its fee. Because an increase in fees to Stephens reduces the effective amount of the interest rate that is ultimately paid to customers, Stephens has a conflict of interest with regard to the Bank Sweep Program. Stephens’ compensation, exclusive of the fees paid to Pershing and IntraFi for the Bank Sweep Program as applied to all clients will not exceed 6% per annum on the aggregate balances in the Deposit Accounts at the program banks. The total amount of the fee Stephens charges affects the amount of interest payable to clients on their Deposit Accounts since the higher Stephens’ fee is, the lower the amount of interest that is paid to Stephens’ clients. Stephens charges investment advisory fees as a percentage of client assets under management which includes cash assets in the Bank Sweep Program. This means that clients will pay Stephens’ investment advisory fee in addition to the fees charged in the Bank Sweep Program which are described above. More information on the current rates of return and fees is available at www.stephens.com/investment-disclosures/ which is incorporated herein. The interest rates on the Deposit Accounts will vary based upon the value of the assets you maintain in your Stephens account, including amounts on deposit in your Deposit Accounts (“Interest Rate Tiers”). The rates and the Interest Rate Tiers may change from time to time. Further information on the Bank Sweep Program is available at www.stephens.com/investment-disclosures/. These disclosures are incorporated herein. The interest rates paid on the Deposit Accounts at a Bank may be higher or lower than the interest rates available to depositors making deposits directly with the Bank or other depository institutions in comparable accounts and for investments in the money market mutual funds and other cash equivalent investments available through Stephens. You should compare the terms, interest rates, required minimum amounts, and other features of the Bank Sweep Program with other accounts and alternative investments. In deciding whether to participate in the Bank Sweep Program, clients should consider the return they are expected to receive versus the safety of the program. Banks participating in the Bank Sweep Program are not selected by Stephens, and each bank participating in the Bank Sweep Program is covered by FDIC deposit insurance up to the applicable FDIC limit. Banks in the program are expected to have acceptable credit but may not have “top tier” credit, and clients should evaluate credit quality and FDIC insurance coverage together with the return they are expected to receive. Custodial Services Stephens entered into a fully disclosed clearing arrangement with Pershing effective November 15, 2019 wherein Pershing provides certain recordkeeping and operational services to Stephens and to Stephens’ clients. The services provided by Pershing include execution and settlement of securities transactions, custody of Stephens’ client accounts and extensions of credit for any margin transactions. ADV Part 2A Appendix 1 March 31, 2025 8  Pershing normally provides custodial account services to Stephens’ clients. Custodial services provided by Pershing include custody of securities in your account, periodic statements, certain tax reporting and other similar services. Pershing is a subsidiary of the Bank of New York Mellon Corporation and is located at One Pershing Plaza, 4th Floor – Jersey City, NJ 07399. Pershing will send your account statements, which you should carefully review. In addition to the account statements Pershing sends you, we may send you a quarterly performance report which among other things, lists your account holdings and performance. You should compare our report to the account statements you receive from Pershing. In the event of any discrepancy between our report and any statement you receive from Pershing regarding the same investment, you should rely on the statement from Pershing. Your account will be subject to the terms and conditions described in the Advisory Contract, Agreement and any separate agreement or agreements executed in connection with the account. Stephens includes custodial fees for custody services and securities services provided by Pershing within the wrap fee charge. If a client’s account is under a wrap fee Program, commission charges are included as part of the Stephens advisory fee unless the client has selected a third party advisor who “trades away” from Pershing. Clients may engage an independent custodian. The fees of any custodian other than Pershing are not covered by the wrap fee and are the separate responsibility of the client. Clients may direct trading through another broker or other execution venue, and, in such a situation, the client will be responsible for all costs and commissions incurred in connection with such trading. Pershing Relationship Pershing is the clearing firm for our securities business. Due to this business relationship, Pershing shares with us a portion of the transaction costs and fees you pay to Pershing for certain transactions and services. This compensation we receive is an additional source of revenue to Stephens, and it defrays our costs associated with maintaining and servicing client accounts. Your advisory fee is not reduced or offset as a result of any revenue that Pershing shares with Stephens. The following is a brief description of some of revenue and other items. • Pershing pays us on a quarterly basis an Active Account Credit in support of our ongoing investment in various businesses, marketing and technology initiatives relating to the services we offer. This Active Account Credit is based on the total number of Stephens client accounts held on the Pershing platform. • Pershing also pays us a Basis Point Credit each quarter which is computed based on the total value of Stephens client accounts held on the Pershing platform. • Pershing also provides consulting and other assistance to us from time to time. • Stephens receives revenues from Pershing on any investor free credit balances. These revenues are not received by Stephens for free credit balances in Employee Retirement Income Security Act (“ERISA”) and Individual Retirement Account (“IRA”) accounts. • Stephens determines the margin debit interest rate and receives any amounts paid by customers in excess of the Fed Funds Target Rate plus 85 basis points. • Stephens determines the interest rate charged to clients who obtain non purpose loans within parameters set by Pershing. Stephens receives 100 bps of the interest paid on the loan from Pershing except in situations where Stephens has agreed to receive a lesser amount. • Pershing pays us a placement fee for each CD purchased through Pershing by a Stephens’ client. • Pershing pays us a portion of the revenues it receives for banking services provided to clients. For the period January 1, 2024 through December 31, 2024, Pershing paid Stephens the following revenues: ADV Part 2A Appendix 1 March 31, 2025 9  Interest based on investor free credit balances of $1,900,734 • A short interest rebate of $1,714,766 • • Margin interest credit of $836,256 • Active account and basis point credits of $1,563,496 • Non Purpose Loan interest of $617,507 • Silver Account (i.e. checking account) fee of $35,750 • Fee Income-Pershing-Legal/Transfer $7,600 • Pershing-Money Market Invesco ATRR $243,432 Where Stephens receives compensation from Pershing, this presents a conflict of interest because Stephens and your FC or IAR have a greater incentive to make available, recommend, or make investment decisions regarding investments and services that provide additional compensation over those investments and services that do not. The Clearing Agreement between Stephens and Pershing is for an initial term of 10 years, and it provides for a substantial termination penalty in the event Stephens terminates the Clearing Agreement prior to the end of the initial term. At the outset of the Clearing Agreement, the termination penalty was $15 million, and it declines $2 million each year to $5 million in years 6 through the end of the Clearing Agreement. The termination penalty serves as a disincentive for Stephens to terminate the Clearing Agreement in the event Stephens or its clients have a negative experience with Pershing or if Stephens believes another firm offers superior service. This creates a conflict of interest in that it could influence Stephens’ decision to remain with Pershing even though it may be in the best interest of Stephens or its clients to terminate the Clearing Agreement. You should only use the cost basis information provided on your custodial account statements for tax reporting purposes. Pershing’s mailing address is Pershing LLC; One Pershing Plaza; Jersey City, New Jersey 07399. For IRA and other retirement accounts, Pershing may charge termination fees pursuant to an adoption agreement you enter into with Pershing, which authorizes Pershing to act as the IRA custodian for Internal Revenue Service purposes. Pershing may resign at any time as the IRA custodian and then you have the right to appoint a successor IRA custodian (Successor). Where an unaffiliated third party acts as custodian of account assets, Stephens does not have discretion to select where cash reserves will be held. The client and/or custodian will make the selection. ERISA and IRA Fees Fees charged by Stephens to accounts of ERISA or Internal Revenue Code (“the Code”) covered plans will comply with the limitations made applicable under ERISA or the Code. Where Stephens or an IAR provides non-discretionary investment advice such as recommending the rollover of a 401k to an IRA account at Stephens, recommending opening an IRA account with Stephens, or recommending the transfer of an IRA from another firm to Stephens, this presents a conflict of interest since compensation will be paid to Stephens and the IAR in connection with these services. In addition, Stephens charges different levels of fees on different investment services. Stephens has adopted policies and procedures to mitigate these conflicts, and to address provisions of and prohibitions under ERISA and the Code with respect to potential conflicts of interest and self-dealing. ERISA Section 408(b)(2) Disclosures ADV Part 2A Appendix 1 March 31, 2025 10  You may be, or may be acting on behalf of, a pension plan governed by the Employee Retirement Income Security Act of 1974, as amended (ERISA). ERISA section 408(b)(2), requires most parties that provide services to employee benefit plans to disclose certain information to a responsible plan fiduciary. Generally, the service provider must disclose the services that it provides to the plan and the compensation that it expects to receive in connection with the services. Stephens’ disclosures are available at the following web address: www.stephens.com/ERISA408b2 If you are the responsible plan fiduciary, please view the disclosures on this website. If you are not the responsible fiduciary, please forward this information to the responsible fiduciary of the plan. Please review this website periodically for any required updates. Principal Transactions Pursuant to SEC Rule 206(3), Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing the capacity in which it is acting. As a practical matter, the above requirements impose delays on the time at which principal transactions can be effected for advisory accounts, and thereby can impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. Investment advisory clients are advised that they have the option to seek execution of transactions recommended by the FC or IAR through broker/dealers other than Stephens. However, on transactions executed through Stephens with Pershing, Stephens or Pershing will not charge a commission to the client, except when an underwriting issue in which Stephens participates is purchased for an account; in this case, the sales concession and underwriting fees are built into the offering price. Stephens will strive to obtain “best execution” of transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances. Transactions in securities in which Stephens acts as a market-maker, or otherwise as a principal will only be affected for clients subject to the client’s written consent to such transaction indicating the quantity and dollar amount of the securities being purchased or sold. If Stephens is acting as a market-maker or otherwise as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a customer. Item 5 Account Requirements and Types of Clients Conditions for Management Generally, a minimum of $250,000 in assets is required for the establishment of investment advisory accounts under the SMID Core program. However, exceptions may be made to this policy. Stephens or the client can terminate SMID Core agreements at any time following advance written notice. Only those clients we deem in our discretion suitable will be accepted into this program. Types of Clients Stephens’ advisory programs are available to individuals, banks, foundations, pension and profit sharing plans, trusts, IRAs, endowments, corporations, partnerships and other entities requiring investment advisory services. ADV Part 2A Appendix 1 March 31, 2025 11  Many of Stephens’ clients are high net worth individuals. We provide investment advice to individuals, trusts, to boards and retirement systems for various governmental pension and retirement plans, to corporate pension and retirement plans, to various foundations and private entities. Additionally, we advise wrap fee accounts in various programs sponsored by affiliated and unaffiliated investment advisers. The sponsor establishes a minimum account size for each program, and you should refer to the sponsor’s wrap fee brochure for a discussion of minimum account sizes and whether the minimum account size can be waived. Only those clients we deem in our discretion suitable will be accepted into these programs. Item 6 Portfolio Manager Selection and Evaluation Affiliated Advisor The SMID Core program engages SIMG to act as a Sub-Advisor and Portfolio Manager for the client’s account. SIMG is an investment adviser registered with the SEC in which affiliates of Stephens hold the entire ownership of voting securities. SIMG provides investment advisory services for separate account clients and for mutual funds known as the American Beacon Stephens Funds® or other funds which may be added from time to time. SIMG also serves as adviser to two collective investment trusts (“CITs”) using its Small Cap Growth and Mid Cap Growth strategies, respectively. Additionally, SIMG serves as an investment advisor to the First Trust Multi-Manager Small Cap Opportunities ETF (MMSC) using its Small Cap Growth Strategy, and as an investment advisor to the following multi-manager mutual funds under our SMID Select Growth Strategy: • Vanguard Explorer™ Fund; and • Bridge Builder Small/Mid Cap Growth Fund. The replacement of SIMG as Sub-Advisor in the SMID Core program may be recommended under the following circumstances: • Change of client’s investment situation or goals; • Sub-Advisor philosophy changes; • Sub-Advisor exposes client’s account to investment style change; • Sub-Advisor firm undergoes ownership change or major personnel change; • Sub-Advisor performance lags peer group benchmarks; • Stephens, in consultation with client, determines to effect a change; or • Sub-Advisor holds an unnecessarily large cash position. In appropriate situations where the client’s investment situation or goals change, Stephens will recommend clients not continue their participation in the SMID Core program. Performance Calculations Stephens relies upon performance information provided from SIMG and third party providers, to determine if SIMG and the SMID Core program are appropriate for the client’s account. Stephens does not regularly audit the calculation of this performance information to ensure that it is calculated on a consistent basis. The performance review includes a comparison of the performance of Sub-Advisors with the performance of selected market indices and peer group averages to evaluate the performance of SIMG over time. ADV Part 2A Appendix 1 March 31, 2025 12  Stephens utilizes a portfolio system licensed from a third party to calculate the performance of client accounts and to prepare portfolio performance reports for clients. To determine the value of securities in your account, Stephens generally relies on third party quotation services. If a price is unavailable or believed to be unreliable, we may determine the price in good faith and may use other sources such as the last recorded transaction. Conflicts of Interest Conflicts of Interest Ownership Pursuant to SEC Rule 206(3), Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing the capacity in which it is acting. As a practical matter, the above requirements may impose delays on the time at which principal transactions may be effected for advisory accounts, and thereby may impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. Transactions in which Stephens acts as a principal will only be effected for clients subject to the client’s written consent to such transaction indicating the quantity and price of the securities being purchased or sold. If Stephens is acting as a market-maker or otherwise as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a client. American Beacon Stephens Funds® and Hotchkis & Wiley Funds (“Affiliated Funds”) are funds managed by affiliates of Stephens and/or advisors in which affiliates of Stephens have a substantial ownership interest. ERISA accounts and IRA accounts are generally prohibited from investing in these Funds. Other advisory accounts may invest in the Affiliated Funds in an appropriate amount if: (1) the manager and the client determine that the investment is suitable for the account, and (2) the client signs an Affiliate Funds Consent Letter (“Consent Letter”) prior to directing the purchase of the affiliated fund shares. Hotchkis and Wiley Limited (“HW-UK”), a wholly-owned subsidiary of H&W, is a private limited company incorporated in England and Wales. HW-UK is an appointed representative and tied agent of Arlington Group Asset Management Limited (AGAM) since March 1, 2016. AGAM is authorized by the Financial Conduct Authority to carry out regulated activities. The Chief Executive of HW-UK is also an appointed representative of AGAM and may carry on certain regulated activities in Europe. Portfolio Management by Advisors Owned or Partially Owned by Stephens Affiliated Mutual Funds Stephens may from time to time engage in transactions on behalf of clients with Hotchkis & Wiley Capital Management LLC (“H&W”) or with mutual funds advised by H&W. H&W is an investment adviser registered with the SEC in which entities under common control with Stephens hold an ownership interest. H&W provides investment advisory services to corporate, pension, public, endowment, foundation, mutual fund and other clients, and H&W also advises its own family of mutual funds. Stephens may also from time to time engage in transactions on behalf of clients with Stephens Investment Management Group LLC (“SIMG”) or with mutual funds advised by SIMG. SIMG is an investment adviser registered with the SEC in which affiliates of Stephens hold the entire ownership of voting securities. SIMG provides investment advisory services for separate account clients and for mutual funds known as the American Beacon Stephens Funds® or other funds which may be added from time to time. ADV Part 2A Appendix 1 March 31, 2025 13  Additionally, SIMG serves as one of the investment advisors to the following multi-manager mutual funds using its SMID Select Growth Strategy or Small Cap Growth Strategy: • Vanguard Explorer™ Fund; and • Bridge Builder Small/Mid Cap Growth Fund; and • First Trust Multi-Manager Small Cap Opportunities ETF (MMSC) H&W advised mutual funds and SIMG advised mutual funds are offered through Stephens’ broker dealer services and/or investment advisory services as part of an investment program. Clients that invest in H&W advised mutual funds or in SIMG advised mutual funds would bear a proportionate share of the fees and expenses of those funds including the management fees or other fees paid to H&W or SIMG. These fees and expenses include commissions or fees, if any, paid to Stephens in connection with portfolio transactions. Please refer to each mutual fund’s prospectus for a full discussion of the fees and expenses of each mutual fund. Stephens Sponsored Wrap Fee Program Stephens sponsors the Stephens Small-Mid Cap Core (“SMID Core”) Growth Program which is a wrap fee program sub-advised by SIMG that follows its SMID Core Growth Model. FCs are not financially incentivized to place clients in the SMID Core Growth Program versus any other wrap program or platform available at Stephens. However, a portion of the SMID Core account fees, generally representing twenty to fifty percent (20%-50%) of SMID Core fees, will be paid to SIMG for its portfolio management services, pursuant to a sub-advisory agreement between Stephens and SIMG. SIMG and Stephens share common ownership, which benefits from the compensation generated to SIMG as the result of a client investing in the SMID Core Growth Program. Depending on the level of trading, the value of the account, and types of securities purchased or sold, clients may be able to obtain transaction execution at a higher or lower cost if purchased separately at Stephens or SIMG than through this wrap fee program. Affiliated Investment Management Activities Certain investment strategies offered by SIMG have been selected for inclusion in the Private Client Group’s (“PCG”) Managed Assets Program (“MAP”). Sub-Advisors and strategies may only participate in MAP if they have been approved by the MAP Investment Committee. The MAP Investment Committee employs a process for evaluating investment managers that includes both qualitative and quantitative factors. SIMG strategies participating in MAP are subject to the same due diligence and evaluation processes as sub-advisors or strategies that have no affiliation with Stephens. FCs are not financially incentivized to favor selecting SIMG strategies over non-affiliated sub-advisors or strategies. However, selection of an SIMG strategy in MAP generates compensation to SIMG, which shares common ownership with Stephens. Other Affiliations Certain entities affiliated with Stephens or under common control with Stephens hold an ownership interest in Alex Brown Realty, LLC, a registered investment adviser. From time to time, Stephens offers to its clients securities sponsored by Alex Brown Realty, LLC. Stephens sometimes refers clients to Stephens Insurance, LLC, an affiliated insurance agency under common control with Stephens, for advice pertaining to products that are provided through Stephens Insurance, LLC, and IARs and FCs may be eligible, subject to regulatory and legal requirements, to receive referral fees for insurance business referred. For further information that pertains to related persons of Stephens, please refer to “Other Potential Conflicts of Interest”. Other Potential Conflicts of Interest ADV Part 2A Appendix 1 March 31, 2025 14  Stephens is a diversified financial services company that directly or through affiliates provides a wide variety of investment banking, securities, insurance and other investment-related services to a broad array of customers. These relationships could give rise to potential conflicts of interest. Any of the following types of transactions could present a potential for a conflict of interest. a) Client account assets can be invested in interests of money market funds, mutual funds, other investment companies, privately offered investment funds and other collective vehicles (collectively, “Funds”) for which Stephens or its affiliates acts as investment advisor, sponsor, administrator, distributor, selling agent, or in other capacities (“Affiliated Funds”). In addition, Client account assets can be invested in interests of Funds for which Stephens or its affiliates do not act as investment adviser, sponsor, administrator or in other capacities. Stephens or its affiliates receive fees for services provided to such Funds, which often include (but are not limited to) fees payable under a plan adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (“12b-1 fees”) and fees paid to compensate Stephens for providing administrative services, distribution services, shareholder services, investment advisory services or other services to or for the benefit of such Funds. Stephens, as a dually-registered broker-dealer, is paid the retail 12b-1 fees for brokerage mutual fund investments. Where 12b-1 fees are received in advisory accounts, these fees are rebated to the client account. b) Client account assets are often invested in transactions that involve or constitute a purchase, sale or other dealings with securities or other instruments for which (i) Stephens, (ii) an affiliate or employee of Stephens, (iii) an entity in which Stephens or an affiliate has a direct or indirect interest, or (iv) another member of a syndicate or other intermediary (where an entity referred to in (i), (ii), or (iii), above is or was a member of the syndicate), has acted, now acts, or in the future may act as an underwriter, syndicate member, market maker, dealer, broker, principal, agent, research analyst or in any other similar capacity, whether the purchase, sale or dealing occurs during the life of the syndicate or after the close of the syndicate. c) Stephens or any other broker-dealer that is or may become affiliated with Stephens (the “affiliated brokers”) is expected to act as broker or dealer to execute transactions on behalf of the client’s account. The client will not be charged a separate fee for brokerage services provided to the account by affiliated brokers. d) Stephens or its affiliates sometimes effect transactions for the client’s account with other accounts for which Stephens or an affiliate provides investment advisory services (“Cross Trades”). Such Cross Trades are intended to enable Stephens to purchase or sell a block of securities at a set price and possibly avoid an unfavorable price movement that may be created through entrance into the market with such purchase or sell order. Stephens typically receives compensation from other accounts involved in a Cross Trade. e) Subject to applicable regulations, Stephens or its affiliates sometimes execute “Agency Cross Transactions” for the client’s account. Agency Cross Transactions are transactions where Stephens, or any affiliate of Stephens, acts as broker for both the client’s account and the other party to the transaction. In such transactions, Stephens, or any of Stephens’ affiliates acting as broker, receives commissions from the other party to such transaction, to the extent permitted by law, in addition to its customary investment management or advisory fee for the client’s account. f) Clients of other divisions of Stephens or clients of other advisory representatives of Stephens or Stephens, its principals, employees, affiliates and their family members, sometimes hold, and sometimes engage in transactions in, securities purchased or sold for the client or about which Stephens gives or has given the client advice. The client’s account may purchase as investments securities of companies with which Stephens or its affiliates maintain investment banking relationships or other relationships or securities of companies in which Stephens or its affiliates have an ownership or other investment interest. ADV Part 2A Appendix 1 March 31, 2025 15  h) Subject to applicable law, Stephens sometimes pays fees to, and/or shares revenues with, affiliates or non-affiliates in connection with referrals for investment advisory accounts. i) Stephens, or its affiliates, may provide more than one type of service to the client (or a related organization), including (but not limited to), investment management services, investment advisory services, financial advisory services, underwriting services, placement agency services, investment banking services, securities brokerage services, securities custodial services, insurance agency services, insurance brokerage services, administrative services or other services, or any combination of services, all on such terms as may be agreed between Stephens (or its affiliate) and client (or its related organization). j) Other divisions and other advisory representatives of Stephens perform investment advisory services for clients other than the client and such other divisions or other advisory representatives of Stephens give advice or take action with respect to other clients that is similar to or different from the advice given or action taken for the client’s account, in terms of securities, timing, nature of transactions and other factors. Stephens will, to the extent practicable, attempt in good faith to allocate investment opportunities among its clients, including the client, on a fair and equitable basis. However, other divisions and other advisory representatives of Stephens will not undertake to make any recommendation or communication to the client with respect to any security which such other divisions or advisory representatives may purchase or sell (either as principal or for any other client’s account) or recommend to any other client, or in which such other divisions or advisory representatives , or their respective principals, employees, affiliates or their family members, may engage in transactions. k) Both advisory and brokerage clients of Stephens have the ability to borrow money against the collateral value of their accounts with non-purpose loans arranged through Stephens with a third party bank. Stephens receives an administrative fee which is paid by the third party bank in an amount which varies but can be up to 1.35% of the monthly outstanding balance of the client’s loan. Part of the administrative fee is passed along to Stephens FCs or IARs, and this can create a conflict of interest. Since Stephens has not compared rates available elsewhere, clients may be able to obtain lower interest rates on their loans through other banks. l) Stephens, Pershing and IntraFi receive fees and benefits for services provided in connection with the Bank Sweep Program. Stephens offers the Bank Sweep Program as a service and is not obligated to offer you this or any sweep product or to make available to you a sweep product that offers a rate of return that is equal to or greater than other comparable products or investments. Stephens has an economic incentive to make available to our clients sweep options that are more profitable to us than other sweep options. Each Bank will pay Stephens a fee equal to a percentage of the average daily deposit balance in your Deposit Accounts at the Bank. Because the Banks pay different amounts, the compensation paid to Stephens will vary from Bank to Bank. Because the interest rates paid to clients are subject to tiers based on the aggregate value of accounts with the client’s Household Balance, Stephens’s compensation rate is higher on client’s cash in lower interest rate tiers and lower on client’s cash balances in higher rate tiers. The differences in Stephens’ compensation from Bank to Bank is intended to ensure that all clients receive the same rate of interest on their Deposit Accounts for their respective interest rate tiers, regardless of the Banks at which the Deposit Accounts are held. Stephens may reduce its fee and may vary the amount of the reductions between clients. Stephens determines its own fee and is compensated by deducting a percentage of the rate paid by Banks for fees paid in connection with the Deposit Accounts. Any increase in Stephens’ fees will decrease the interest that you will receive in connection with the Deposit Accounts and any decrease in Stephens’ fees will increase the interest that you will receive in connection with the Deposit Accounts. Therefore, Stephens ADV Part 2A Appendix 1 March 31, 2025 16  has a conflict of interest with regard to the Bank Sweep Program, as any increase in the fee Stephens chooses to receive will decrease the amount of interest received by customers. The fee will vary from Bank to Bank. The interest rate tiers create a conflict of interest, as they incentivize Stephens to execute buy transactions in your account prior to the first business day following the fifteenth (15th) of the month, and sell transactions after the first business day following the fifteenth (15th) of the month, therefore permitting Stephens to retain more of the fee payable on the Deposit Accounts. Stephens charges advisory accounts an investment advisory fee based on a percentage of client assets. In computing your investment advisory fee, cash balances in the Bank Sweep Program are included in the assets of your account when calculating the investment advisory fee earned by Stephens for management of your account. Therefore, Stephens is paid both its fee from the Banks on the Bank Sweep Program balance in your account, and, in addition, Stephens earns an investment advisory fee for your total balances in your account, including your balance in the Bank Sweep Program. This creates a conflict of interest, as Stephens earns more from Bank Sweep Program balances in investment advisory accounts than it would if such balances were held outside of the Bank Sweep Program or outside of the investment advisory account entirely, creating an economic incentive for Stephens to retain advisory assets in cash in the Bank Sweep Program. Your FC or IAR does not receive a portion of the fee paid to Stephens by the Banks. Conflict of Interest with Personal Trading and Client Trades To minimize potential conflicts of interest, advisory personnel who determine or approve what recommendations will be made for client accounts will not participate in Stephens’ proprietary trading activities and will not know what trading strategies are employed for its proprietary accounts. Stephens allows employees to make purchases in the marketplace of securities owned by any client account, provided that such purchases are made in amounts consistent with the normal investment practice of the person involved. Such purchases must be made after the investment advisory accounts managed by such employee (or in the management of which such employee participates) has completed its transactions in such securities. Under certain circumstances, employee transactions may be permitted prior to full completion of the investment advisory division’s transactions. Such exceptions require prior approval of the Chief Compliance Officer or his designee and will only be granted after considering factors such as the time element involved in filling the order, market considerations, etc. Stephens Personal Trading Stephens’ personnel may not participate in initial public offerings. All employees are required to maintain their personal accounts and accounts in which they have a beneficial interest at Stephens unless the account has been specifically exempt in writing from this requirement. Stephens’ employees are required to provide copies of all of their trade confirmations and brokerage account statements to Stephens’ Compliance Department in order to permit the monitoring of compliance with personal trading policies and restrictions. Additionally, employees are required to report all personal securities transactions no less frequently than quarterly. Stephens’ Code requires employees to report violations of the Code to the Stephens Chief Compliance Officer or his designee. Stephens Insured Bank Sweep Program Stephens makes available to clients whose accounts are custodied at Pershing the opportunity to participate in the Bank Sweep Program. In this program all of the uninvested cash in a client’s account is automatically deposited, or “swept” into FDIC insured, interest-bearing deposit accounts at one or more banks which participate in the Bank Sweep Program. None of the banks participating in the Bank Sweep Program are owned by or affiliated with Stephens. When a client signs an account agreement with Stephens, ADV Part 2A Appendix 1 March 31, 2025 17  participation in the Bank Sweep Program is automatic unless the client elects not to participate and “opts out” of the Bank Sweep Program. For more information about the Bank Sweep Program please review these important disclosures at www.stephens.com/investment-disclosures/ which are incorporated by reference into this Form ADV Part 2 brochure. Stephens offers the Bank Sweep Program as a service and is not obligated to offer this or any sweep product or to make available to a sweep product that offers a rate of return that is equal to or greater than other comparable products or investments. The interest rates paid on Deposit Accounts at a Bank may be higher or lower than the interest rates available to depositors making deposits directly with the Bank or other depository institutions in comparable accounts and for investments in other cash equivalent investments through Stephens. The Bank Sweep Program is not available to ERISA plans with accounts at Stephens such as employee benefit plans, retirement plans, defined contribution plans, defined benefit plans (collectively, “ERISA accounts”), or to traditional and rollover IRA accounts, Roth, SEP, SIMPLE and inherited individual retirement accounts (“IRAs”); Keogh plans; and Coverdell education savings accounts. Uninvested cash in ERISA and IRA accounts is swept into money market mutual funds selected by the client. The Bank Sweep Program is designed to temporarily hold cash balances in your investment account, and is not designed to act as a retail bank account, nor a long-term, ongoing investment option. If you desire, as part of an investment strategy or otherwise, to maintain a cash position in your Stephens account for other than a short period of time and/or are seeking the highest yields currently available in the market for your cash balances, please contact your FC or IAR to discuss investment options that are available outside of the Bank Sweep Program to help maximize your potential return consistent with your investment objectives, liquidity needs and risk tolerance. Please note, however, that available cash accumulating in your Stephens account will not be automatically swept into any investment you purchase outside of the Bank Sweep Program. Nothing obligates you to participate in the Bank Sweep Program. You may receive a higher rate of return through products offered outside the Bank Sweep Program, including Money Market Funds offered through your account with Stephens and Pershing. Each Deposit Account constitutes a direct obligation of the Bank and is not directly or indirectly an obligation of Stephens or Pershing. Stephens and Pershing do not guarantee in any way the financial condition of the Banks and are not responsible for any insured or uninsured portion of a Deposit Account. Stephens and Pershing will not charge commissions on securities transactions that are executed through Stephens or Pershing for these accounts. Your account would be responsible to pay any commission charges imposed by any other brokerage firm on any securities transactions executed through any other brokerage firm, and such charges would be in addition to the wrap fee and any other applicable charges incurred by your account. By executing trades through Stephens with Pershing, your account might forego benefits, such as participation in block trades or negotiated transactions that might be available through other brokerage firms. Bank Sweep Program If you have on deposit through the Bank Sweep Program an amount of cash that exceeds the number of Banks multiplied by $250,000, the balances in excess of this amount will not be insured by the FDIC. In the event of a failure of a bank participating in the Bank Sweep Program, there may be a time period during which you may not be able to access your cash. If you have cash at a bank outside the Bank Sweep Program, this may negatively impact the availability of FDIC insurance for the total amount of your funds held within and outside the Bank Sweep Program. ADV Part 2A Appendix 1 March 31, 2025 18  Advisory Services Clients in the SMID Core program are choosing to invest a portion of their assets in a program managed pursuant to the portfolio manager’s investment strategy rather than a unique program tailored for their particular investment circumstances. Clients can impose reasonable investment restrictions on the Portfolio Manager of their account, such as restrictions on investing in particular securities or types of securities or restrictions on investing in particular industries. Restrictions In this program, you can impose reasonable restrictions on account investments. For example, you may restrict Stephens from buying specific securities, a category of securities (e.g., tobacco companies) or Fund shares. If you restrict a category of securities, we will determine which specific securities fall within the restricted category. In doing so, we can rely on outside sources (e.g., standard industry codes and research provided by independent service providers). Any restrictions you impose on individual securities have no effect on Fund holdings since Funds operate in accordance with the investment objectives and strategies described in their prospectuses. In this program, the portion of the account that would have been invested in any restricted security or category of securities will be invested in cash or cash equivalents. This will impact the performance of the account relative to an account that is fully invested in securities. Wrap Fee Programs In addition to other indications of individual ownership, including the right to withdraw, hypothecate, vote, or pledge securities held in the wrap fee client’s account, a wrap fee client has the ability to place reasonable limitations and/or restrictions on the investments in their portfolio. Where reasonable restrictions are imposed, Stephens will manage the client’s portfolio investments to comply with these restrictions, but the investment performance of the client’s account will likely differ (positively or negatively) from other clients following a similar investment strategy, that is not subject to the same restrictions. The minimum account size for wrap fee programs varies from program to program, and a person considering a wrap fee program should review the disclosure document provided by Stephens of the applicable program for details regarding the operation of the program, its risks, fees, and other charges. In the SMID Core program, the entire wrap fee is paid to Stephens for its services related to each wrap fee account. In determining the suitability of an investment strategy for a particular wrap fee program client, we rely on the information provided by the client regarding the financial objectives of the client for each account. This information comes from, among other sources, personal interviews with the client and written questionnaires completed by the client and other communications with the client or its representative regarding the client’s situation, investment objectives, risk tolerances and investment restrictions, if any. Our strategies are not appropriate for all investors, and investors should only invest a portion of their portfolio in these programs. In separately managed accounts Stephens advises, SIMG has the discretionary authority to determine the securities, and the amount of securities, to be bought and sold for our clients without obtaining specific client consent. The discretionary authority regarding investments may, however, be subject to certain reasonable restrictions and limitations placed by the client on transactions in certain types of securities or industries, restrictions or limitations imposed by applicable regulations. Performance-Based Fees and Side-By-Side Management Stephens typically charges clients an investment advisory wrap fee based on the value of the assets in the client’s account. On occasion, Stephens enters into performance fee arrangements with appropriate clients as discussed below. Only certain clients qualify for performance fee arrangements which compensate Stephens based, in part, on the performance of the client’s account. ADV Part 2A Appendix 1 March 31, 2025 19  All fees are negotiable and vary depending on the size of the investment, the nature of the services to be rendered by Stephens to the client, and other factors. Performance-based fees are typically invoiced annually. Should Stephens determine to engage in performance-based fees, any such fee arrangement would be negotiated with the client on an individualized basis. The performance fee arrangement could create an incentive for Stephens to seek to maximize the investment return by making investments that are subject to greater risk, or are more speculative, than would be the case if Stephens’ compensation were not based upon the investment return or could create an incentive for Stephens to seek to limit investment returns by pursuing investments with reduced risk. With a performance fee arrangement Stephens’ fee is contingent upon the returns on the client’s assets, which is computed based upon unrealized and realized appreciation or depreciation of the client’s assets. Accounts participating in a performance fee arrangement may pay Stephens more compensation, or less compensation, when compared to standard fee rates. Performance fee arrangements are not available for all investment accounts and must be approved by Stephens on a case-by-case basis. Performance fee rates are negotiable. A client may negotiate a base fee rate, performance fee rates, an index to be used to calculate the performance fee, or the use of no index in calculating the performance fee. Any performance fee that Stephens charges is intended to comply with Rule 205-3 and other applicable requirements under the Investment Advisers Act of 1940. Stephens has an incentive to favor accounts which it charges a performance fee over other types of client accounts by allocating more profitable investments to performance fee accounts or by devoting more resources toward the accounts’ management. Stephens seeks to mitigate the potential conflicts of interest which arise from managing accounts that bear a performance fee through its policies and procedures, including those related to investment allocation, and by complying with the provisions of Rule 205-3 as stated above. Stephens has discretion not to accept these arrangements. Methods of Analysis, Investment Strategies and Risk of Loss We utilize street and independent sources for our research, but it is not the sole basis of our investment decision making process. Other sources of information we utilize can include industry data obtained from subscription services, company filings, street research and models. We utilize these services for real-time news and pricing. We also utilize other independent research sources for quantitative reports that measure such things as price changes, growth rates, profitability, valuation, earnings surprises and earnings revisions. These quantitative reports are used to help identify new securities that meet our investment criteria and to monitor existing holdings. Investing in securities involves risk of loss that clients should be prepared to bear. The material risks associated with our strategies are: Equity Market Risk – Overall stock market risks affect the value of the investments in equity strategies. Factors such as U.S. economic growth and market conditions, interest rates, and political events affect the equity markets. Money Market Risk - An investment in a Money Market Fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although the fund seeks to preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in the fund. Yields will vary. Yield quotations more closely reflect the current earnings of the fund than the total return. Management Risk - Our judgments about the attractiveness and potential appreciation of a particular asset class, mutual funds or individual security may be incorrect and there is no guarantee that individual ADV Part 2A Appendix 1 March 31, 2025 20  securities will perform as anticipated. The price of an individual security can be more volatile than the market as a whole and our investment thesis on a particular stock may fail to produce the intended results. Small Cap and Mid Cap Company Risk - Investing in small cap and mid cap issuers involves a significantly greater risk than investing in larger, more established companies. The daily trading volume for small cap and mid cap issuers can be much lower than for more widely held, established companies. There may be periods when it is difficult to invest in or liquidate portfolio investments for our various investment strategies. This is particularly the case when breaking news on a company occurs or when significant market forces and events occur. In addition, small and mid-cap companies are more vulnerable to economic, market and industry changes. Because smaller companies often have limited product lines, markets or financial resources, or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than larger capitalization companies. Investors should only invest a portion of their total portfolios in these securities, and investors should be prepared to lose their entire investments. Certain Risks Associated with Cybersecurity. With the increased use of technologies such as the Internet to conduct business, investment advisers, including Stephens rely in part on digital and network technologies (collectively, “cyber networks”). These cyber networks are susceptible to operational, information security and related risks and can be at risk of cyber-attacks. Cyber-attacks could seek unauthorized access to cyber networks for the purpose of misappropriating sensitive information, corrupting data, or causing operational disruptions. Cyber-attacks can potentially be carried out against the issuers of securities you have invested in, against third party service providers, or against Stephens itself by persons using techniques that range from efforts to circumvent network security, overwhelm websites, and gather intelligence through the use of social media in order to obtain information necessary to gain access to cyber networks. Although cyber-attacks potentially could occur, Stephens maintains an information technology security policy and technical and physical safeguards intended to protect the confidentiality of internal data. Bank Sweep Program If you have on deposit through the Bank Sweep Program an amount of cash that exceeds the number of Banks multiplied by $250,000, the balances in excess of this amount will not be insured by the FDIC. In the event of a failure of a bank participating in the Bank Sweep Program, there may be a time period during which you may not be able to access your cash. If you have cash at a bank outside the Bank Sweep Program, this may negatively impact the availability of FDIC insurance for the total amount of your funds held within and outside the Bank Sweep Program. You are responsible for monitoring the total amount of deposits that you hold with any one Bank, directly or through an intermediary, in order to determine the extent of FDIC insurance coverage available to you on your deposits, including the Deposit Accounts. Policies and Procedures for Proxy Voting Stephens will make available information of the firm’s proxy voting policy and procedures including information regarding how Stephens voted proxies, if requested. In response to any request as to how the client’s proxies were voted, the Chief Compliance Officer or his designee would provide the information to the client. Unless directed otherwise, SIMG will vote proxies for the securities held in SMID accounts in the manner it determines to be in the best interest of the SMID account clients. ADV Part 2A Appendix 1 March 31, 2025 21  Clients may obtain a copy of SIMG’s Proxy Voting Policy and/or information on how SIMG voted the client’s securities upon written request sent to SIMG, LLC. If the client chooses to have their securities custodied away from Pershing it will be the responsibility of the client to vote or to arrange for the voting of their proxies. Corporate Actions Or Other Matters From time to time there may also be a variety of corporate actions or other matters for which shareholder action is required or solicited and with respect to which Stephens may take action that it deems appropriate in its best judgment except to the extent otherwise required by agreement with the client. These actions include, for example and without limitation, responding to tender offers or exchange offers, bankruptcy proceedings and proposed class action settlements. However, Stephens will have no power, authority, responsibility or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in the client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. Item 7 Client Information Provided to Portfolio Managers In the SMID Core program, Stephens acts as the registered investment advisor establishing a separate account for the client. A separate account is a portfolio of individual securities privately managed by a Sub-Advisor. The FC or IAR assists clients in determining whether the SMID Core program is suitable for a portion of their overall portfolio. The FC or IAR assigned to the account and support personnel have access to the client’s data maintained by Stephens, and the client’s financial information and other data is available to SIMG. Stephens maintains client information and objectives for the SMID Core program. A Stephens account application and agreement must be completed by each client and maintained by Stephens. The Stephens account application contains account name and address, investment objectives and specific financial information. Client information may be updated from time to time upon notification to Stephens of any material changes and noted within the client’s file. Additionally, we advise wrap fee accounts in various programs sponsored by affiliated and unaffiliated investment advisers. The sponsor establishes a minimum account size for each program, and you should refer to the sponsor’s wrap fee brochure for a discussion of minimum account sizes and whether the minimum account size can be waived. Information regarding each client’s financial situation and investment objectives is made available to the Portfolio Managers upon its initial receipt from the client and when it is updated. Item 8 Client Contact with Portfolio Managers The Stephens FC or IAR assigned to the client’s account is the client’s primary point of contact with Stephens. The Stephens FC or IAR offers to discuss or meet no less frequently than annually with SMID Core program clients. Clients are encouraged to contact the Stephens FC or IAR at any time if they have questions or would like to have additional discussions or meetings. If you have experienced any changes regarding your financial status, investment objectives or risk tolerance, please contact your FC or IAR to see if any adjustments are necessary to your investment strategy. ADV Part 2A Appendix 1 March 31, 2025 22  Clients in the SMID program are not restricted in their ability to contact or consult with SIMG regarding their SMID account. Item 9 Additional Information Disciplinary Information Stephens voluntarily participated in the SEC’s Share Class Selection Disclosure Initiative, and on March 11, 2019 the SEC entered a Cease and Desist Order against Stephens in which Stephens neither admitted nor denied the allegations of the SEC’s Order. The Order alleged that Stephens did not fully disclose conflicts of interest related to the selection of mutual fund share classes for its advisory clients, and that Stephens purchased, recommended or held mutual fund share classes for client accounts which paid Stephens 12b-1 fees when less expensive share classes of the same funds were available which did not pay Stephens these 12b-1 fees. The Order directed Stephens to Cease and Desist from committing or causing any violations and any future violations of Sections 206(2) and 207 of the Investment Advisers Act of 1940 and ordered that Stephens be censured and pay disgorgement and prejudgment interest to advisory clients who held these more expensive mutual funds share classes in their advisory accounts. (IA Release No. 40- 5196) In its capacity as a broker/dealer, Stephens has been subject to legal or disciplinary events in the ordinary course of its business, such as regulatory sanctions relating to compliance with broker/dealer trade reporting requirements and other regulatory actions. Affiliations Stephens, from time to time, enters into arrangements with other broker-dealers, investment advisors or other persons whereby such parties refer clients seeking advisory services to Stephens. For additional information regarding Stephens’ affiliations, please see Item 6 “Conflicts of Interest” above. Code of Ethics Stephens has adopted an Investment Advisory Code of Ethics (“Code”), which defines the requirements and expectations for the business conduct of all of its investment advisory employees, including employees of Stephens. Furthermore, all Stephens’ employees are expected to adhere to Stephens’ Mission and Values Statement and Code of Professional Conduct. The fundamental position of Stephens is that all aspects of its business are to be conducted in an ethical and legal manner in accordance with federal law and the laws of all states where the investment advisory divisions do business. In accordance with that position general principles apply: • The interests of Stephens’ clients are our first consideration. Any personal securities transaction, which would be detrimental or potentially detrimental to any client account and any personal securities transaction, which is designed to profit by the market effect of any client account, must be avoided. • All personal securities transactions should be conducted in such a manner as to be consistent with the Code and to avoid actual or potential conflicts of interest or abuse of a Stephens’ employee’s knowledge of customer information or customer transactions. ADV Part 2A Appendix 1 March 31, 2025 23  • Investment adviser personnel should not take inappropriate advantage of their positions. Information concerning the identity of security holdings and financial circumstances of clients is confidential. Independence in the investment decision-making process is paramount. • Accordingly, there are certain standards of conduct, which Stephens investment advisory employees follow to reduce potential conflicts with the interests of our clients. Stephens will provide a copy of the Code to any client or prospective client upon request. Supervision and Review of Accounts The SMID Core program is overseen by Joseph Warren Simpson, or his designee who serves as Stephens’ Supervisory Principal for the SMID Core program. Client account review reports are prepared and provided to clients on a quarterly basis. The quarterly review reports disclose all transactions and the performance of each component of the account. The FC or IAR assigned to a client’s account will be the primary contact for the client at Stephens. The FC or IAR will offer to meet with clients periodically to discuss their investment portfolio and investment goals, but no less frequently than annually. Clients are encouraged to contact their Stephens FC or IAR at any time if the client would like to have additional discussions or meetings. Primary responsibility for the supervision of these accounts lies with the Supervisory Principal, Warren Simpson and/or his designee. Mr. Simpson is responsible for serving as liaison between Stephens FC or IAR and SIMG. Mr. Simpson, or his designee, also coordinates account set up and client profile reviews and account implementation. The Supervisory Principal responsibilities are to review client accounts and coordinate with Stephens’ FCs or IARs regarding account performance and suitability. Internal Stephens’ reports and reports from the FCs or IARs and SIMG are relied upon in the overall review process. Supervisory Principals are responsible for supervisory approval of new advisory accounts, the daily review of trading activity and periodic reviews of performance utilizing various other daily and monthly exception reports. When Stephens executes a transaction for you through a Pershing order execution system, you will receive a written or electronic confirmation of the transaction which provides information regarding the transaction. You will also receive a written or electronic monthly account statement if you had activity in your account during the month which will detail the activity and the positions in your account. If you have not had any activity during the month and you have positions in your account, you will receive a written or electronic quarterly account statement which details the positions in your account. You may waive the receipt of account statements or confirmations after each trade in favor of e-delivery via https://stephensaccess.netxinvestor.com/. You may also receive mutual fund prospectuses, where appropriate. In addition, we provide account reports for client accounts reflecting account holdings and account performance on a quarterly basis. Client Referrals and Other Compensation Neither Stephens nor any of our employees receives sales awards or other prizes from any non-affiliated outside parties for providing investment advice to our clients. ADV Part 2A Appendix 1 March 31, 2025 24  Stephens may enter into referral arrangements with its affiliates or between divisions of the Firm. This includes referrals to Stephens of prospective clients seeking investment advisory services. If the referral results in a new account relationship, then a portion of the net revenue from such account is paid to such entity or division as a referral fee, and such entity or division may pay some portion of the fee to the referring person. This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. Such arrangements are conducted in accordance with the Marketing Rule, as applicable, and the Advisers Act generally. FCs are eligible to receive referral fees for referring eligible clients to the Stephens Investment Banking division. For eligible investment banking referrals, referring parties are eligible to receive compensation as a percentage of net income earned by Investment Banking. Therefore, FCs are incentivized to refer clients to the Investment Banking division. Any such compensation to the FC is at the discretion of the Firm. Financial Information Stephens does not require or solicit prepayment of more than $1200 in fees per client six months or more in advance and, thus, has not included a balance sheet of its most recent fiscal year. Stephens is not aware of any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to our clients. Who to Contact We are pleased to have an opportunity to serve as your investment adviser. If you have any questions about the information contained in this brochure or about any aspect of the services we provide, please do not hesitate to call Stephens at (877-891-0095). Clients often receive this information by electronic delivery. The Stephens ADV and additional brochures are available at www.stephens.com/investment- disclosures/. To access your FC or IAR's SEC Advisor Biography, go to www.stephens.com , use the search bar in the top right corner of the home page and search by your FC's name. SEC Advisor Biographies are also available in the "Our Team" section and are there for your review. ADV Part 2A Appendix 1 March 31, 2025 25  Definitions and Professional Designation Qualifications Accredited Investment Fiduciary® (AIF®) The Accredited Investment Fiduciary (AIF®) Designation is a professional certification that demonstrates an advisor or other person serving as an investment fiduciary has met certain requirements to earn and maintain the credential. The purpose of the Accredited Investment Fiduciary (AIF®) Designation is to assure that those responsible for managing or advising on investor assets have a fundamental understanding of the principles of fiduciary duty, the standards of conduct for acting as a fiduciary, and a process for carrying out fiduciary responsibility. The AIF® training curriculum is offered in distance education or a blended learning option to suit each Candidate's needs. Fi360’s Prudent Investment Practices cover four Steps (domains), twenty-one Practices (tasks), and seventy-nine Criteria that an investment fiduciary is expected to be able to perform. After passing the exam, a Candidate wishing to file for the AIF® designation must submit the accreditation application and accreditation fee. Six Hours of annual continuing education is required, a minimum of four of which must be delivered by Fi360 or one of Fi360's approved CE providers. Accredited Wealth Management AdvisorSM (AWMA® ) Individuals who hold the AWMA® designation have completed a course of study encompassing wealth strategies, equity-based compensation plans, tax reduction alternatives, and asset protection alternatives. Additionally, individuals must pass an end-of-course examination that tests their ability to synthesize complex concepts and apply theoretical concepts to real-life situations. All designees have agreed to adhere to Standards of Professional Conduct and are subject to a disciplinary process. Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standards of Professional Conduct and complying with self-disclosure requirements. The Chartered Financial Analyst (CFA) The CFA designation is awarded to investment professionals who have successfully completed the requirements set forth by the CFA Institute. CFA Institute has a long-standing history of and commitment to establishing a broadly accepted ethical standard for calculating and presenting investment performance based on the principles of fair representation and full disclosure. The goals in developing and evolving the Global Investment Performance Standards (GIPS) are to establish them as the recognized standard for calculating and presenting investment performance around the world and for the GIPS standards to become a firm’s “passport” to market investment management services globally. The CFA Institute is an international non-profit organization whose stated mission is to promote and develop a high level of educational, ethical and professional standards in the investment industry. To be eligible for the CFA designation, candidates must pass 3 examinations that test the academic portion of the CFA program, possess a bachelor’s degree from an accredited educational institution or equivalent, and have 48 months of acceptable professional work experience. The CFA curriculum includes the following subject areas: Ethical and Professional Standards; Quantitative Methods (such as the time value of money, and statistical inference); Economics; Financial Reporting and Analysis; Corporate Finance; Analysis of Investments (such as stocks and bonds); and Portfolio Management and Analysis (asset allocation, portfolio risk, and performance measurement). CERTIFIED FINANCIAL PLANNER™ (CFP®) ADV Part 2A Appendix 1 March 31, 2025 26  To earn the CFP® designation, an individual must complete a college-level course of study addressing the financial planning subject areas determined by the Certified Financial Planner Board of Standards, Inc. (“CFP Board”), pass a comprehensive two-day examination developed by the CFP Board and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university) and demonstrate three years of full-time work experience in financial planning or a related field. CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning. CFP®s are require to complete 30 credit hours of continuing education accepted by CFP Board every to two years, including 2 hours of CFP Board-approved Ethics CE. Chartered Financial Consultant® (ChFC®) The ChFC® Program offers comprehensive education in the essentials of financial planning, including insurance, taxation, retirement, and estate planning. It also addresses advanced areas such as behavioral finance, non-traditional family structures, and small business planning. There are no prerequisite courses required before you can begin the ChFC® Program, but to use the designation, you are required to have three years of full-time, relevant business experience and a high school diploma or the equivalent. To receive and maintain the ChFC® designation, you must agree to comply with The American College Code of Ethics and Procedures and participate in the annual Professional Recertification Program (PRP) to maintain the designation. Certified Investment Management Analyst (CIMA) The CIMA certification signifies that an individual has met initial and on-going experience, ethical, education, and examination requirements for investment management consulting, including advanced investment management theory and application. Prerequisites for the CIMA certification are three years of financial services experience and an acceptable regulatory history. To obtain the CIMA certification, candidates must pass an online Certification Examination. The Certification Examination is a five-hour examination and has 125 multiple-choice questions and 15 non- scored, pretest questions. Each examination item (question) is related to an area of work performed by an investment management consultant/advisor. The topics have been identified through a job analysis. All examination items are written in a four-option, multiple-choice format. CIMA designees are required to adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and Guidelines for Use of the Marks. CIMA designees must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through Investment Management Consultants Association (IMCA). Certified Pension Consultant (CPC) The Certified Pension Consultant (CPC) credential is conferred by ASPPA to benefits professionals working in plan administration, pension actuarial administration, insurance and financial planning. CPCs work alongside employers to formulate, implement, administer and maintain qualified retirement plans. The CPC is the capstone credential, or highest credential, currently conferred by ASPPA. To earn the CPC credential, you must successful complete various exams, verify a minimum of two years’ experience in the retirement plan industry, provide two letters of recommendation and apply for the ASPPA credentialed membership. All credentialed members must acquire 40 hours of continuing education (CE) credits (2 of which must be Ethics) in a two-year cycle and renew their ASPPA Membership annually to retain their credential(s). The Certified Portfolio Manager (CPM®) ADV Part 2A Appendix 1 March 31, 2025 27  The Certified Portfolio Manager (CPM®) designation is a collaboration of the Academy of Certified Portfolio Managers and Columbia University. The academic component is designed to provide a deeper understanding of fundamental security analysis, asset allocation, and portfolio management concepts for financial services industry professionals managing discretionary portfolios. The curriculum encompasses eight core concepts: • Quantitative Methods • Financial Statement Analysis • Corporate Finance • Fixed Income Analysis • Equity Analysis • Fiduciary Responsibility • Derivatives • Qualifying for the CPM® designation The current criteria for applicant eligibility are any of the following (1) A certificate, diploma or academic degree providing evidence of a four-year undergraduate degree (2) 3 years of employment in the financial services industry and (3) Letter of recommendation on behalf of the applicant who is employed in the financial services industry, written by a supervisor, where the credential requirements are desired for the training and development of the applicant. At the end of each calendar year, ACPM members are required to submit the following; Record of 20 completed continuing education hours. ACPM maintains a self- auditing continuing education policy. Answers to a series of Professional Conduct questions. Annual membership dues. All three items are due by December 31st of that calendar year. Certified Public Accountant (CPA) CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally include minimum college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting), minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA), and successful passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of continuing professional education (CPE) activities on an ongoing basis. Additionally, all American Institute of Certified Public Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct. Chartered Retirement Planning Counselor SM (CRPC®) The CRPC® is conferred by the College for Financial Planning. Individuals who hold the CRPC® designation have completed a course of study encompassing pre-and post-retirement needs, asset management, estate planning and the entire retirement planning process using models and techniques from real client situations. Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standard of Professional Conduct and complying with self-disclosure requirements. Chartered Retirement Planning Specialist SM (CRPS®) The CRPS® is conferred by the College for Financial Planning. Individuals who hold the CRPS® designation have completed a course of study encompassing the specialization in creating, implementing and maintaining retirement plans for businesses. They must pass an exam demonstrating their expertise. Successful applicants earn the right to use the CRPS designation with their names for two years. Designees ADV Part 2A Appendix 1 March 31, 2025 28  renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standard of Professional Conduct and complying with self-disclosure requirements. Qualified Plan Financial Consultant (QPFC) QPFC is the professional credential for financial professionals who sell, advise, market or support qualified retirement plans. The QPFC program provides an understanding of general retirement planning concepts, terminology, distinctive features of qualified plans and the role of retirement plan professionals. QPFC is for professionals with two to three years of retirement plan experience. A candidate will be expected to demonstrate a general proficiency of plan administration, compliance, investment, fiduciary, and ethics issues. The QPFC credential is available as an alternative to the CPFA® credential. The coursework and exam are the same for both credentials. Candidates must complete the NAPA CPFA® exam, agree to abide by the ARA Code of Professional Conduct, and apply for the credential. In order to maintain the credential, designees must complete 10 CE hours per calendar year, starting the year following when the designation was earned. . ADV Part 2A Appendix 1 March 31, 2025 29 

SEC File No: 801-15510 Stephens Inc. 111 Center Street Little Rock, Arkansas 72201-4430 StephensChoice 877-891-0095 Website: www.stephens.com. March 31, 2025 Uniform Application for Investment Advisor Registration This wrap fee program brochure provides information about the qualifications and business practices of Stephens Inc. If you have any questions about the contents of this brochure, please contact us at 877-891- 0095 or www.stephens.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. information about Stephens Inc. also is available on the SEC’s website at Additional www.adviserinfo.sec.gov. Stephens Inc. is a registered investment adviser with the United States Securities and Exchange Commission. Registration does not imply a certain level of skill or training. ADV Part 2A Appendix 1 March 31, 2025 1  Item 2 Material Changes This is an annual amendment to the StephensChoice wrap fee program brochure. This section identifies and discusses material changes since the last annual update dated March 28, 2024. For more details, please see the item in this brochure referred to in the summary below. Item 9 was updated to disclose: (i) payments employees of Stephens Inc. and its affiliates can receive for referring prospective clients seeking investment advisory services, and (ii) payments Financial Consultants and Investment Advisor Representatives are eligible to receive for making referrals to Stephens Inc.’s Investment Banking division. ADV Part 2A Appendix 1 March 31, 2025 2  Item 3 Table of Contents StephensChoice ......................................................................................................................................... 1 Item 2 Material Changes .............................................................................................................................. 2 Item 3 Table of Contents .............................................................................................................................. 3 Item 4 Services, Fees and Compensation .................................................................................................... 4 StephensChoice Program ............................................................................................................................. 4 Mutual Fund Strategy .............................................................................................................................. 4 For Plan Sponsor/Trustee Directed Accounts ........................................................................................ 4 Participant Directed Accounts................................................................................................................. 5 SC Strategy Changes ................................................................................................................................ 5 Fees ............................................................................................................................................................ 5 Fee Schedule .............................................................................................................................................. 6 Is a Wrap Fee Arrangement for you? ..................................................................................................... 6 Collection of Fees ...................................................................................................................................... 7 Plan Services Agreement.......................................................................................................................... 7 Other types of Fees and Expenses Clients May Pay .............................................................................. 8 Item 5 Account Requirements and Types of Clients ................................................................................13 Conditions for Management ...................................................................................................................13 Item 6 Portfolio Manager Selection and Evaluation ................................................................................13 Advisory Representative’s Education and Business Standards ..........................................................13 Selection of Fund Managers ...................................................................................................................14 Performance Calculations .......................................................................................................................14 Advisory Services.....................................................................................................................................15 SC Wrap Fee Program ............................................................................................................................17 Conflicts of Interest .................................................................................................................................17 Portfolio Management by Advisors Owned or Partially Owned by Stephens ...................................18 Other Potential Conflicts of Interest ......................................................................................................20 Performance-Based Fees and Side-By-Side Management ...................................................................22 Methods of Analysis, Investment Strategies and Risk of Loss .............................................................22 Policies and Procedures for Proxy Voting .............................................................................................24 Item 7 Client Information Provided to Portfolio Managers ....................................................................25 Item 8 Client Contact with Portfolio Managers ........................................................................................26 Client Meetings ........................................................................................................................................26 Item 9 Additional Information ...................................................................................................................26 Disciplinary Information ........................................................................................................................26 Affiliations ................................................................................................................................................26 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................26 Stephens Personal Trading .....................................................................................................................27 Conflict of Interest with Personal Trading and Client Trades ............................................................27 Client Referrals and Other Compensation ............................................................................................28 Supervision and Review of Accounts .....................................................................................................28 Financial Information .............................................................................................................................29 Who to Contact ............................................................................................................................................29 ADV Part 2A Appendix 1 March 31, 2025 3  Item 4 Services, Fees and Compensation Stephens Inc. ("Stephens") is an Arkansas corporation which registered with the Securities and Exchange Commission (“SEC”) as a broker-dealer in September 1946. Stephens registered as an investment advisor with the SEC on September 19, 1980 and began providing investment advisory services at the time. Stephens is a full service broker-dealer and investment bank. In addition to being registered with the SEC, Stephens is a member of the Financial Industry Regulatory Authority (“FINRA”), the New York Stock Exchange, Inc. (“NYSE”), the NYSE American LLC (“NYSE-AMEX”), the Municipal Securities Rulemaking Board (MSRB), the Investors’ Exchange LLC (“IEX”) and the Securities Investor Protection Corporation (“SIPC”). Stephens derives greater revenues from its broker-dealer and investment banking activities than it derives from its investment advisor activities. Affiliates of Stephens are also separately engaged in financial services businesses, including merchant banking, insurance and investment advisory businesses. StephensChoice Program The StephensChoice Program (“SC”) is a platform designed by Stephens to assist qualified retirement plans or other deferred compensation programs (“Plan”) with establishing an appropriate line-up of “no load” or “load waived” mutual funds chosen through Stephens’ process of selection of mutual funds representing a range of designated asset classes to achieve appropriate asset allocation portfolios for the investment of plan assets. Mutual Fund Strategy The SC standard line-up is comprised of one or more actively managed mutual funds and/or passive index funds representing each asset class included in the SC program. Stephens establishes and communicates to the Plan Sponsor and/or Trustee such investment line-up and, if chosen by the Plan Sponsor and/or Trustee, a menu of five asset allocation models (each, an “SC Model”) for differing risk profiles. investment selection, monitoring, fund replacement, Stephens provides ongoing investment performance measurement and quarterly reporting throughout the life of the account. In addition, periodic rebalancing is provided in certain accounts which are introduced to our clearing broker-dealer Pershing and custodied at Pershing. Services are provided pursuant to a Plan Services Agreement described below. For Plan Sponsor/Trustee Directed Accounts Based on individual consultations with the Plan Sponsor and/or Trustee and a risk tolerance questionnaire, one of the five SC Models will be chosen for each trustee-directed account or for segregated participant accounts. The selected SC Model is intended to reflect the investment objectives, risk tolerance and investment time horizon communicated to Stephens by the Plan Sponsor and/or Trustee. Following the selection of the SC Model, Stephens will initiate and execute the transactions that are required to invest the account in ADV Part 2A Appendix 1 March 31, 2025 4  accordance with such SC Model’s asset allocation. Best execution is sought for all transactions. Participant Directed Accounts For Plans with participant directed accounts, the Plan Sponsor and/or Trustee makes the determination to use the SC line-up of funds, which Plan participants may elect to use in their individual accounts. If requested, Stephens will conduct group education and enrollment meetings to educate participants on the investment options in the Plan. Following initial enrollment, Stephens is available to communicate with individual Plan participants on an as needed basis, for educational purposes about their Plan account. SC Strategy Changes Stephens may periodically change the mutual funds representing any asset class in the standard SC line-up of funds, or add or eliminate asset classes from the standard SC platform line-up. Stephens communicates such changes in the standard line-up to the Plan Sponsor and/or Trustee. The Plan Sponsor and/or Trustee has discretion to adopt or decline such changes, unless Stephens has been designated as a 3(38) fiduciary. Fees Fees for the SC program will be billed to the Plan Sponsor and/or Plan Trustee or deducted from client’s Plan participants’ account assets. Stephens collects fees from the client’s account(s) quarterly in arrears. In accounts for which Pershing acts as custodian, rates are set forth in the Plan Service Agreement and based on the daily average value of the assets in the account(s) for that calendar quarter. If the client uses a custodian other than Pershing, Stephens’ fee will be collected by the outside custodian and may be based on a different quarterly accounting method. The SC program is a “wrap fee program” in which the client pays a single fee for investment advisory services and related services, which unless otherwise provided will include executions, custody and clearing charges. Fees for other services, such as administrative or transfer fees will be charged at Stephens’ standard rates in addition to the wrap fee. Additionally, fees charged by the mutual funds included in each client’s portfolio will be borne by the Plan or Plan participant. Mutual funds typically charge an expense ratio to pay for portfolio management, administration, marketing, distribution, and other expenses. Additionally, many mutual fund companies impose (among other fees) short-term trading fees with respect to any purchase and redemptions of fund shares effected within a time frame designated by the mutual fund company (such as, but not limited to sixty (60) or ninety (90) days). Mutual fund companies may also impose other fees from time to time. Any fees imposed by any mutual fund company with respect to SC account assets will be charged to the account, whether resulting from fund transfers, withdrawals, rebalancing transactions, or other transactions in the account. Accounts that elect to use third-party custodians or third-party brokerage services will bear the costs of such third party services in addition to the fees payable to Stephens. ADV Part 2A Appendix 1 March 31, 2025 5  The services provided under the Plan Service Agreement contemplate that the Plan Sponsor and/or Trustee will invest plan assets in investment company securities (“Mutual Funds”). Individual Mutual Funds may pay fees to Pershing as a result of these investments if Pershing is custodian. The existence and amounts of such Mutual Fund fees is more fully described in the fund prospectus for each Mutual Fund in which client assets may be invested. These fees will be passed through to the Plan Sponsor and/or Trustee’s account and/or the Plan participant’s account and will be reinvested in the account, or if Pershing is not the custodian, as described in the Agreement with the third party custodians and administrators. Fee Schedule Annual Account Fee: Contract Assets Asset Charge Scale First $1,000,000 0.85% Next $1,000,000 0.70% Next $1,000,000 0.50% Next $2,000,000 0.30% Next $5,000,000 0.10% Over $10 Million* *Fees Negotiated on Assets in Excess of $10,000,000. The annual fee percentage is based on the projected assets at the end of the year. The fee percent will remain constant through the year unless actual assets significantly increase or decrease and an adjustment is mutually agreed upon by the Plan and Stephens Capital Management. The percentage fee is applied to the average daily asset value for the calendar quarter and billed or deducted from plan assets following the quarter end, if Pershing is acting as custodian. If Pershing is not acting as custodian the fee may be based on a different quarterly accounting method. Any payments received by Stephens Inc. and/or Pershing from any mutual fund company based on assets held in the Plan will be credited to the account. Any payments received by a third party custodian from any mutual fund company based on assets held in the Plan will be also rebated to the account or as described in the Agreement between the custodian and Plan. Any revenue that the firm realizes in connection with an advisory account is typically credited back to the Plan. Is a Wrap Fee Arrangement for you? ADV Part 2A Appendix 1 March 31, 2025 6  The SC program is a “wrap fee program” in which the client pays a single fee for investment advisory services and related services, which unless otherwise provided will include executions, custody and clearing charges. See the section entitled, “Other types of Fees and Expenses Clients May Pay” for additional details. The wrap fee is charged according to the Fee Schedule as described in the previous section. The SC wrap fee program may cost the client more or less than purchasing such services separately depending upon such factors as trading activity, account size and investment adviser minimums for non-wrap accounts. We encourage you to carefully consider your options in establishing or maintaining an advisory fee-based account. As a general matter, a fee-based advisory account approach may be considered appropriate for customers who rely on investment advice or investment management services or who engage in moderate to high levels of trading activity. A fee-based approach can be more economical for customers who engage in active trading, since the price per trade is reduced as the number of trades increases under a fee-based approach. However, fee- based advisory account arrangements may not be appropriate for customers who rely primarily on their own independent resources and judgments for making their investment selections and decisions and do not wish to purchase advisory services. Customers who engage in a lower level of trading activity might prefer a traditional brokerage account with a commission payable on each transaction, particularly if the customer typically does not utilize advisory services for trading decisions, as transaction cost savings might be realized in the context of a traditional pay-per-trade commission structure. Typically, a portion of any revenue that the firm realizes in connection with an advisory account will be included in the calculation of the compensation to be paid by the firm to the investment advisory account representative; and, therefore, the investment advisory account representative will experience conflicts of interest similar to those experienced by the firm. Collection of Fees Stephens, through Pershing, is authorized to deduct from the account each quarter in arrears the amount of the total quarterly wrap fee as described in the Plan Services Agreement, and the other fees if any, applicable to client accounts for such calendar quarter. For accounts not held at Pershing, the Plan’s outside custodian will debit Stephens’ fee per the agreement between the Plan and the outside custodian. Alternatively, the Plan Sponsor and/or Trustee may choose to be billed and to pay the fees from the Sponsor’s or Trustee’s assets not included within the Plan. Service fees and other transactions charges, if any, will be applied to the account as incurred. The portion of the total fee that is paid to the Investment Advisory Representative is 40% of the gross fee. Plan Services Agreement Entering into an agreement for the SC program involves the execution by client of a Plan Services Agreement and/or a general account agreement. Any party to the agreement, upon written notice to the other parties, may terminate the agreement. The term of the agreement is generally for a period of one year beginning on the effective date of the agreement and is automatically renewed for successive additional one-year terms without further action. ADV Part 2A Appendix 1 March 31, 2025 7  At the time of entering into such agreement, the client has a right to terminate the agreement without penalty within five (5) business days after entering into the agreement and receive a full refund of any investment advisory fees paid to Stephens. At any time, either the client or Stephens may terminate the contract without penalty, upon reasonable notice (“Notice”) given in writing to the other party hereto. If the account is to be liquidated as the result of a party giving Notice, it is understood that Stephens through Pershing may take up to five (5) trading days to effect such liquidation following the date the liquidation request was received by Stephens. If Plan assets are custodied somewhere other than Pershing, liquidation as the result of termination may be subject to the terms of the agreement between the Plan and the outside custodian. Termination of the agreement will not affect the liabilities or obligations of the parties arising from transactions initiated prior to termination. Each client agrees to pay Stephens’ reasonable fees, costs and expenses of collection, including attorney fees, for any unpaid balances under the contract. If the Plan terminates an account service arrangement and transfers the Plan account to a different financial firm, a transfer fee, currently $100, will apply to the transfer. After a party gives Notice, a quarterly interim fee will continue to be applied until all assets invested in the SC program or platform have been removed from the Plan account. From time to time, only in special circumstances, the fees may be negotiable or otherwise varied. These fee arrangements could include a flat fee. Fees will be payable on a schedule as negotiated by the parties. On June 5, 2019, the Securities and Exchange Commission issued its interpretation of the Standard of Conduct for Investment Advisers and rescinded certain previously issued no action letters. As a result of these changes, Stephens will not seek to enforce any provision of an investment advisory agreement with a retail investor which discharges Stephens or its agents from liability to the retail investor client. Other types of Fees and Expenses Clients May Pay The wrap fee covers custody services and securities execution services provided by Stephens for the account. Clients may engage an independent custodian. The fees of any custodian other than Pershing are not covered by the wrap fee and are the separate responsibility of the client. Clients may direct trading through another broker or other execution venue, and, in such a situation, the client will be responsible for all costs and commissions incurred in connection with such directed trading. Fees for other services, such as administrative or transfer fees will be charged at Stephens’ standard rates in addition to the wrap fee. In this Stephens’ advisory program, Stephens will select and recommend money market mutual funds, or comparable investments, in which to hold cash reserves, but the selections are limited to investments authorized by Pershing in its capacity as custodian. The alternatives authorized by Stephens include select money market mutual funds and from time to time its in-house pending reinvestment account. In most accounts, cash balances arising from the sales of securities, redemption of debt securities, Mutual Fund 12b-1 fees, ADV Part 2A Appendix 1 March 31, 2025 8  dividend and interest payments and funds received from clients not otherwise invested, are invested automatically on a daily basis in a money market mutual fund designated by client or selected on a discretionary basis by Stephens. Funds placed in a client’s account by personal check usually will be invested within two business days after deposit to the selected money market mutual fund. Due to the foregoing practices, Stephens may obtain federal funds prior to the date that deposits are credited to client accounts and thus may realize some economic benefit because of the delay in investing these funds. If an unaffiliated third party acts as custodian of account assets, typically the custodian and the client, not Stephens, would determine where cash reserves will be held. Mutual Funds Mutual Funds available through the program are limited to fund families with which Stephens, Pershing or the outside custodian has a selling agreement and which may be purchased on a no-load or load waived basis. SC program fees are based on the assumption that each client’s account assets will be invested in mutual funds included in the SC program. In any event, Stephens will comply with Rule 205-3 of the Investment Advisers Act of 1940. Individual Mutual Funds may pay fees to Stephens as a result of these investments if Pershing is custodian. The existence and amounts of such Mutual Fund fees is disclosed in the fund prospectus for each Mutual Fund in which client assets may be invested. These fees will be passed through to the client’s and/or Plan participant’s account and will be reinvested in the account, or if Pershing is not the custodian, as described in the Agreement with the third party custodians and administrators. In some instances, individual Mutual Funds pay Stephens a portion or share of their revenue. Such revenue shares are not reflected in the individual Mutual Funds’ prospectuses. Any revenue shares Stephens receives from individual Mutual Funds will be passed through to the clients’ and/or Plan participants’ accounts and will be reinvested in the account. Stephens takes into account any revenue shares that will be passed through to the client when identifying and selecting the most efficient share class of individual Mutual Funds. If Pershing is not the custodian, the most efficient share class will be identified and selected by the third party custodians and administrators. For both Affiliated Funds and Unaffiliated Funds in which Stephens’ client assets are invested, Stephens receives shareholder servicing fees and 12b-1 fees from Funds on an ongoing basis as compensation for the administrative, distribution and shareholder services provided by Stephens. These services include such things as record maintenance, shareholder communications, transactional services, client tax information, reports filings and similar such services. These fees are paid under a plan adopted by the Funds pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended. If Stephens receives 12b-1 fees from a Fund with respect to a client’s mutual fund ADV Part 2A Appendix 1 March 31, 2025 9  investment in the client’s account and the client is paying Stephens an advisory fee on such investment, 12b-1 fees will be rebated to the advisory client. However, in client brokerage accounts, which have mutual fund holdings, Stephens does retain the 12b-1 fees and shareholder servicing fees paid by the funds on these mutual fund holdings Stephens has entered into a fully disclosed clearing arrangement with Pershing wherein Pershing will provide certain recordkeeping and operational services to Stephens and to some SC clients. The services provided by Pershing will include execution and settlement of securities transactions, custody of Stephens’ client accounts and extensions of credit for any margin transactions. This clearing arrangement became effective after the close of business on November 15, 2019. Mutual funds are available to investors in a variety of different share classes, all of which carry different expense ratios. Fund share classes that pay higher compensation carry higher expense ratios than share classes of the same mutual fund with lower expense ratios. Investing in a mutual fund share class with a higher expense ratio will negatively impact an investor’s return. Consistent with our fiduciary duty to clients, Stephens will take reasonable steps to ensure advisory clients are invested in share classes of mutual funds with the most appropriate expense ratio for their advisory account. Not all share classes are available to advisory clients of Stephens, and it is possible that cheaper share classes of a fund may be available directly with the fund not available on the Pershing platform or away from Stephens. Additionally, because of the large number of mutual funds which are offered in an ever changing variety of different share classes, it is possible that investors may not receive cheaper share classes which come available after their initial investment in a fund. Money Market Mutual Funds In the Stephens’ advisory programs, assets not otherwise invested would typically be invested in money market mutual funds, or comparable investments, in which to hold cash reserves. The selections are limited to investments authorized by Stephens with Pershing in its capacity as custodian. Money market mutual funds often pay Stephens a distribution fee on assets invested in the fund through Stephens. The revenue to Stephens is in addition to the fees that are received from these accounts. In most accounts, cash balances arising from the sales of securities, redemption of debt securities, Mutual Fund 12b-1 fees, dividend and interest payments and funds received from clients not otherwise invested are automatically invested on a daily basis in a money market mutual fund designated by client or selected on a discretionary basis by Stephens. Funds placed in a client’s account by personal check usually will be invested in a money market mutual fund within two business days after deposited with Stephens. Due to the foregoing practices, Stephens earns interest on such funds prior to the date that deposits are credited to client accounts and, thus, realizes some economic benefit because of the timing of the investment of these funds. Custodial Services Stephens’ clearing broker-dealer, Pershing, normally provides custodial account services to Stephens’ clients. Custodial services provided by Pershing include custody of securities ADV Part 2A Appendix 1 March 31, 2025 10  in your account, periodic statements, certain tax reporting and other similar services. Pershing is a subsidiary of the Bank of New York Mellon Corporation, and is located at One Pershing Plaza, 4th Floor – Jersey City, NJ 07399. Pershing will send your account statements, which you should carefully review. In addition to the account statements Pershing sends you, we may send you a quarterly performance report which among other things, lists your account holdings and performance. You should compare our report to the account statements you receive from Pershing. In the event of any discrepancy between our report and any statement you receive from Pershing regarding the same investment, you should rely on the statement from Pershing. Your account will be subject to the terms and conditions described in the Plan Services Agreement and any separate agreement or agreements executed in connection with the account. Stephens includes custodial fees for custody services and securities services provided by Pershing within the “wrap” fee charge. If a client’s account is under a “wrap” fee program, commission charges are included as part of the Stephens advisory fee unless the client has selected a third party adviser who “trades away” from Pershing. Clients may engage an independent custodian. The fees of any custodian other than Pershing are not covered by the “wrap” fee and are the separate responsibility of the client. Clients may direct trading through another broker or other execution venue, and, in such a situation, the client will be responsible for all costs and commissions incurred in connection with such trading. Pershing Relationship Pershing is the clearing firm for our securities business. Due to this business relationship, Pershing shares with us a portion of the transaction costs and fees you pay to Pershing for certain transactions and services. This compensation we receive is an additional source of revenue to Stephens, and it defrays our costs associated with maintaining and servicing client accounts. Your advisory fee is not reduced or offset as a result of any revenue that Pershing shares with Stephens. The following is a brief description of such revenue and other items. • Pershing pays us on a quarterly basis an Active Account Credit in support of our ongoing investment in various businesses, marketing and technology initiatives relating to the services we offer. This Active Account Credit is based on the total number of Stephens client accounts held on the Pershing platform. • Pershing also pays us a Basis Point Credit each quarter which is computed based on the total value of Stephens client accounts held on the Pershing platform. • Pershing also provides consulting and other assistance to us from time to time. • Stephens receives revenues from Pershing on any investor free credit balances. These revenues are not received by Stephens for free credit balances in Employee Retirement Income Security Act (“ERISA”) and Individual Retirement Account (“IRA”) accounts. • Stephens determines the margin debit interest rate and receives any amounts paid by customers in excess of the Fed Funds Target Rate plus 85 basis points. ADV Part 2A Appendix 1 March 31, 2025 11  • Stephens determines the interest rate charged to clients who obtain non purpose loans within parameters set by Pershing. Stephens receives 100 bps of the interest paid on the loan from Pershing except in situations where Stephens has agreed to receive a lesser amount. • Pershing pays us a placement fee for each CD purchased through Pershing by a Stephens client. • Pershing pays us a portion of the revenues it receives for banking services provided to clients. For the period of January 1, 2024 through December 31, 2024, Pershing paid Stephens the following revenues: Interest based on investor free credit balances of $1,900,734 • A short interest rebate of $1,714,766 • • Margin interest credit of $836,256 • Active account and basis point credits of $1,563,496 • Non Purpose Loan interest of $617,507 • Silver Account (i.e. checking account) fee of $35,750 • Fee Income-Pershing-Legal/Transfer $7,600 • Pershing-Money Market Invesco ATRR $243,432 Where Stephens receives compensation from Pershing, this presents a conflict of interest because Stephens and your Investment Advisory Representative have a greater incentive to make available, recommend, or make investment decisions regarding investments and services that provide additional compensation over those investments and services that do not. The Clearing Agreement between Stephens and Pershing is for an initial term of 10 years, and it provides for a substantial termination penalty in the event Stephens terminates the Clearing Agreement prior to the end of the initial term. At the outset of the Clearing Agreement, the termination penalty was $15 million, and it declines $2 million each year to $5 million in years 6 through the end of the Clearing Agreement. The termination penalty serves as a disincentive for Stephens to terminate the Clearing Agreement in the event Stephens or its clients have a negative experience with Pershing or if Stephens believes another firm offers superior service. This creates a conflict of interest in that it could influence Stephens’ decision to remain with Pershing even though it may be in the best interest of Stephens or its clients to terminate the Clearing Agreement. You should only use the cost basis information provided on your custodial account statements for tax reporting purposes. Pershing’s mailing address is: Pershing LLC; One Pershing Plaza; Jersey City, New Jersey 07399. ADV Part 2A Appendix 1 March 31, 2025 12  Where an unaffiliated third party acts as custodian of account assets, Stephens does not have discretion to select where cash reserves will be held. The client and/or custodian will make the selection. ERISA Fees Fees charged by Stephens to accounts of ERISA covered plans will comply with the limitations made applicable under ERISA. Stephens has adopted policies and procedures to mitigate conflicts, and to address provisions of and prohibitions under ERISA with respect to potential conflicts of interest and self-dealing. ERISA Section 408(b)(2) Disclosures You may be, or may be acting on behalf of, a pension plan governed by the Employee Retirement Income Security Act of 1974, as amended (ERISA). ERISA section 408(b)(2), requires most parties that provide services to employee benefit plans to disclose certain information to a responsible plan fiduciary. Generally, the service provider must disclose the services that it provides to the plan and the compensation that it expects to receive in connection with the services. disclosures are available at the following web address: Stephens’s www.stephens.com/ERISA408b2 If you are the responsible plan fiduciary, please view the disclosures on this website and the website of the Third Party Administrator (“TPA”) of your plan. If you are not the responsible fiduciary, please forward this information to the responsible fiduciary of the plan. Please review this website periodically for any required updates. Item 5 Account Requirements and Types of Clients Conditions for Management Stephens does not require a minimum account balance for the establishment of an account under the SC program. Stephens or the client can terminate an SC agreement at any time following advance written notice. Only those clients we deem in our discretion suitable will be accepted into this program. Item 6 Portfolio Manager Selection and Evaluation Advisory Representative’s Education and Business Standards As a general rule, Stephens requires each Investment Advisory Representative (“IAR”) to have a college degree and extensive experience with securities brokers, investment advisers, asset managers, investment bankers, financial institutions, insurance companies, or equivalent institutions. Such standards may be waived in exceptional cases. All IAR’s are employees of Stephens. The selection of an IAR for a particular client is based on a number of factors including experience, client preferences and performance. ADV Part 2A Appendix 1 March 31, 2025 13  Selection of Fund Managers The SC selection process is a four step proprietary process for actively managed mutual fund selection. The SC process begins with Morningstar’s database of over 23,000 actively managed mutual funds and screens these funds through a filter of initial criteria that includes objectives such as three year manager tenure, five year inception date, size of fund and three and five year performance numbers. From this screening, the process takes semi- finalists and screens those funds on both a quantitative and qualitative analysis. On a quantitative basis, Stephens then evaluates such factors as annual performance; standard deviation, which measures volatility of returns; R squared, which measures the relationship of returns to the benchmark; and alpha, which measures excess returns due to manager’s skill. On a qualitative basis, Stephens also evaluates such factors as a deeper understanding of the fund’s investment philosophy, an understanding of trading disciplines for buying and selling of securities and knowledge of the configuration of the portfolio management team. If possible, the process continues with an in-person or virtual due diligence visit to funds considered potential finalists in the selection process and the choosing of a selected fund and an alternate fund per asset class by the SC Investment Committee. The relationship with the selected funds is established to provide for a regular flow of communication and materials from such funds. This funds selection process results in many different mutual fund companies being represented on the SC platform, as Stephens attempts to identify a “Best of Breed” mutual fund for each asset class on the platform. Once chosen, selected actively managed funds are regularly monitored by Stephens. Once a client approves the investment line-up, the client’s account may be established and assets invested in the SC line-up of mutual funds. In the case of a Trustee directed plan, the client’s assets will be invested pursuant to the asset allocation model selected by the Plan Sponsor and/or Trustee. In the case of a participant directed plan, assets will be invested pursuant to the SC Model the Plan participants select or the asset allocation the Plan participants develop from the SC line-up of mutual funds. In some participant directed plans, Plan participants may also have the option to select a custom glide path product that automatically adjusts the mix of funds to become less risky over time based on the participant’s time horizon parameters. Performance Calculations The performance review includes a comparison of the performance of the funds with the performance of selected market indices and peer group averages to assist in evaluating the performance of funds over time. Throughout the quarter, the actively managed funds are regularly monitored for performance and other news. The StephensChoice Investment Committee meets periodically to compare the line-up of mutual funds on performance to selected investment ADV Part 2A Appendix 1 March 31, 2025 14  benchmarks and evaluate other criteria relating to the operation of the funds. If warning signs are observed, a fund may be subjected to a probationary review and comparative analysis. Warning signs typically are based upon factors such as style inconsistency, manager changes, performance issues or changes in investment philosophy. Upon completion of the probationary review, the investment committee will determine whether that fund will remain in the standard SC line-up of mutual funds or be replaced with an alternate fund in that asset class. To determine the value of securities in your account, Stephens generally relies on third party quotation services and on the net asset value of mutual fund shares as reported by the funds or third party services. If a price is unavailable or believed to be unreliable, Stephens may determine the price in good faith and may use other sources such as the last recorded transaction. For further information that pertains to other investment advisory firms related to Stephens and other related persons of Stephens, please refer to “Other Potential Conflicts of Interest.” Advisory Services Investment Committee The SC Program is overseen and reviewed by the StephensChoice Investment Committee, which is composed of: Mimi Myer Hurst, CFA – Chairperson Edward Frost, CPC Steven Lawrence Middleton Saul M. Rousseau Warren Simpson Bo Brister Doug Seelicke Services provided under the SC program include: providing the SC platform, selecting the asset classes, as well as adding or deleting asset classes included in the platform, monitoring the mutual funds made available through the platform, recommending additions to or deletions from the line-up of mutual funds made available through the platform, asset allocation modeling, quarterly performance reports and, when requested, risk based or age based profiling. With respect to SC accounts in the SC program, the assigned IAR at Stephens is responsible for reviewing performance of the accounts with the client periodically. The day-to-day investment decisions and security selections are made by the clients or Plan participants from among the investment choices made available through the platform. Mutual fund distributions are generally reinvested in the respective fund. When Pershing acts as custodian, mutual funds transactions will be executed by Stephens in SC accounts based upon the instructions of the clients or Plan participants. Periodic rebalancing in certain accounts custodied at Pershing is also provided. The goal of the SC program is to assist clients by attempting to bring together, into a single platform, a line-up of mutual funds capable of creating reasonable returns with reduced risk through ADV Part 2A Appendix 1 March 31, 2025 15  an investment strategy, consistent with client’s investment profile, that utilizes a diversified portfolio in which each asset class represented in the portfolio is managed by professional mutual fund managers. Other services that may be provided under the SC program include: assistance in defining client’s investment goals, periodic rebalancing, account support and automated billing. Liaison Services If requested by the Plan, Stephens may assist the Plan with liaison services to help the Plan establish an account with a new Plan custodian or to help the Plan transfer assets of the Plan to a new custodian. Stephens may provide liaison services to help the Plan establish accounts with third-party providers of record keeping and administration services to the Plan or liaison services to help with communications relating to the discussion and resolution of administrative issues related to the Plan’s operations or to its relationships with the third party providers of record keeping, administration and custodial services to the Plan; and liaison services to help the Plan with the development of education and enrollment packets for Plan participants or prospective Plan participants. Educational Services If requested by the Plan, Stephens may assist the Plan with its conducting of individual or group education and/or enrollment meetings with Plan participants on dates agreed upon. The educational services may include a discussion of enrollment materials, investment alternatives available under the Plan, potential investment objectives, potential risks associated with different investment approaches, potential effects of portfolio diversification, the potential effects of different investment time horizons and other aspects of Plan participation or investing through the Plan. In addition, if requested by the Plan, Stephens may assist the Plan with preparing the investment information required to be provided to Plan participants by the “identified plan fiduciary” under §404(c) of ERISA, as described in DOL Reg. 2550.404(c)-1(b)(2)(i)(B)(I), prior to or coincident with the participant’s enrollment in the Plan, and will assist the Plan with preparing the information described in DOL Reg. 2550.404(c) 1(b)(2)(i)(B)(2). Other Services For accounts that are held away from Stephens, it is contemplated that third party providers of Plan services (other than Stephens) will provide actuarial, record keeping, administration, brokerage, clearance, settlement and custodial services to the Plan, and that none of such services will be provided by Stephens, unless Stephens and the Plan enter into a separate subsequent written agreement describing such services and setting forth the terms and conditions on which such services would be provided. Stephens and the Plan contemplate that dividends and distributions (other than liquidating distributions) received on investments held through the Plan will generally be reinvested into the investment that paid the dividend or distribution and that Plan portfolios designed to pursue an asset allocation model will be rebalanced from time to time to promote adherence to the selected model. ADV Part 2A Appendix 1 March 31, 2025 16  Trading Authorization In connection with the SC program, when acting as custodian, Stephens through Pershing shall buy or sell securities for the client’s account in accordance with the directions of the client. If Pershing is not acting as custodian, the Plan Sponsor and/or Trustee or the participant will direct the custodian to buy or sell securities for the client’s account. If authorized by the client for its SC assets, Stephens will have authority to reinvest dividends and other income distributions on behalf of SC accounts and to rebalance client portfolios on a periodic basis. Each client may from time to time request a modification of the asset allocation or withdraw assets from the SC program, subject to limitations adopted by Stephens on the frequency of such changes. SC Wrap Fee Program In addition to other indications of individual ownership, including the right to withdraw, hypothecate, vote or pledge securities held in the wrap fee client’s account, a wrap fee client has the ability to place limitations and/or restrictions on the investments in their portfolio. Where restrictions are imposed, Stephens will manage the client’s portfolio investments to comply with these restrictions, but the investment performance of the client’s account will likely differ (positively or negatively) from other clients following a similar investment strategy, that is not subject to the same restrictions. The minimum account size for wrap fee programs varies from program to program, and a person considering a wrap fee program should review the disclosure document provided by Stephens of the applicable program for details regarding the operation of the program, its risks, fees, and other charges. In the SC program, the entire wrap fee is paid to Stephens for its services relating to each wrap fee account. In determining the suitability of an investment strategy for a particular wrap fee program, Stephens relies on the information provided by the client regarding the financial objectives of the client for each account. This information comes from, among other sources, personal interviews with the client and written questionnaires completed by the client and other communications with the client or its representative regarding the client’s situation, investment objectives, risk tolerances and investment restrictions, if any. Conflicts of Interest Conflicts of Interest Ownership Pursuant to SEC Rule 206(3), Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing the capacity in which it is acting. As a practical matter, the above requirements may impose delays on the time at which principal transactions may be effected for advisory accounts, and thereby may impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. ADV Part 2A Appendix 1 March 31, 2025 17  Transactions in which Stephens acts as a principal will only be effected for clients subject to the client’s written consent to such transaction indicating the quantity and price of the securities being purchased or sold. If Stephens is acting as a market-maker or otherwise as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a client. American Beacon Stephens Funds® and Hotchkis & Wiley Funds (“Affiliated Funds”) are funds managed by affiliates of Stephens and/or advisors in which affiliates of Stephens have a substantial ownership interest. ERISA accounts and IRA accounts are generally prohibited from investing in these Funds. Other advisory accounts may invest in the Affiliated Funds in an appropriate amount if: (1) the manager and the client determine that the investment is suitable for the account, and (2) the client signs an Affiliate Funds Consent Letter (“Consent Letter”) prior to directing the purchase of the affiliated fund shares. Hotchkis and Wiley Limited (“HW-UK”), a wholly-owned subsidiary of H&W, is a private limited company incorporated in England and Wales. HW-UK is an appointed representative and tied agent of Arlington Group Asset Management Limited (AGAM) since March 1, 2016. AGAM is authorized by the Financial Conduct Authority to carry out regulated activities. The Chief Executive of HW-UK is also an appointed representative of AGAM and may carry on certain regulated activities in Europe. Portfolio Management by Advisors Owned or Partially Owned by Stephens Affiliated Mutual Funds Stephens may from time to time engage in transactions on behalf of clients with Hotchkis & Wiley Capital Management LLC (“H&W”) or with mutual funds advised by H&W. H&W is an investment adviser registered with the SEC in which entities under common control with Stephens hold an ownership interest. H&W provides investment advisory services to corporate, pension, public, endowment, foundation, mutual fund and other clients, and H&W also advises its own family of mutual funds. Stephens may also from time to time engage in transactions on behalf of clients with Stephens Investment Management Group LLC (“SIMG”) or with mutual funds advised by SIMG. SIMG is an investment adviser registered with the SEC in which affiliates of Stephens hold the entire ownership of voting securities. SIMG provides investment advisory services for separate account clients and for mutual funds known as the American Beacon Stephens Funds® or other funds which may be added from time to time. Additionally, SIMG serves as one of the investment advisors to the following multi- manager mutual funds using its SMID Select Growth Strategy or Small Cap Growth Strategy: • Vanguard Explorer™ Fund; and • Bridge Builder Small/Mid Cap Growth Fund; and • First Trust Multi-Manager Small Cap Opportunities ETF (MMSC) ADV Part 2A Appendix 1 March 31, 2025 18  H&W advised mutual funds and SIMG advised mutual funds are offered through Stephens’ broker dealer services and/or investment advisory services as part of an investment program. Clients that invest in H&W advised mutual funds or in SIMG advised mutual funds would bear a proportionate share of the fees and expenses of those funds including the management fees or other fees paid to H&W or SIMG. These fees and expenses include commissions or fees, if any, paid to Stephens in connection with portfolio transactions. Please refer to each mutual fund’s prospectus for a full discussion of the fees and expenses of each mutual fund. Stephens Sponsored Wrap Fee Program Stephens sponsors the Stephens Small-Mid Cap Core (“SMID Core”) Growth Program which is a wrap fee program sub-advised by SIMG that follows its SMID Core Growth Model. IARs are not financially incentivized to place clients in the SMID Core Growth Program versus any other wrap program or platform available at Stephens. However, a portion of the SMID Core account fees, generally representing twenty to fifty percent (20%-50%) of SMID Core fees, will be paid to SIMG for its portfolio management services, pursuant to a sub-advisory agreement between Stephens and SIMG. SIMG and Stephens share common ownership, which benefits from the compensation generated to SIMG as the result of a client investing in the SMID Core Growth Program. Depending on the level of trading, the value of the account, and types of securities purchased or sold, clients may be able to obtain transaction execution at a higher or lower cost if purchased separately at Stephens or SIMG than through this wrap fee program. Affiliated Investment Management Activities Certain investment strategies offered by SIMG have been selected for inclusion in the Private Client Group’s (“PCG”) Managed Assets Program (“MAP”). Sub-Advisors and strategies may only participate in MAP if they have been approved by the MAP Investment Committee. The MAP Investment Committee employs a process for evaluating investment managers that includes both qualitative and quantitative factors. SIMG strategies participating in MAP are subject to the same due diligence and evaluation processes as sub-advisors or strategies that have no affiliation with Stephens. IARs are not financially incentivized to favor selecting SIMG strategies over non- affiliated sub-advisors or strategies. However, selection of an SIMG strategy in MAP generates compensation to SIMG, which shares common ownership with Stephens. Other Affiliations Certain entities affiliated with Stephens or under common control with Stephens hold an ownership interest in Alex Brown Realty, LLC, a registered investment adviser. From time to time, Stephens offers to its clients securities sponsored by Alex Brown Realty, LLC. Stephens sometimes refers clients to Stephens Insurance, LLC, an affiliated insurance agency under common control with Stephens, for advice pertaining to products that are provided through Stephens Insurance, LLC, and Investment Advisor Representatives and Financial Consultants may be eligible, subject to regulatory and legal requirements, to receive referral fees for insurance business referred. ADV Part 2A Appendix 1 March 31, 2025 19  For further information that pertains to related persons of Stephens, please refer to “Other Potential Conflicts of Interest” below. Other Potential Conflicts of Interest Stephens is a diversified financial services company that directly or through affiliates provides a wide variety of investment banking, securities, insurance and other investment- related services to a broad array of customers. These relationships could give rise to potential conflicts of interest. Any of the following types of transactions could present a potential for a conflict of interest. a) Client account assets can be invested in interests of money market funds, mutual funds, other investment companies, privately offered investment funds and other collective vehicles (collectively, “Funds”) for which Stephens or its affiliates acts as investment advisor, sponsor, administrator, distributor, selling agent, or in other capacities (“Affiliated Funds”). In addition, client account assets may be invested in interests of Funds for which Stephens or its affiliates do not act as investment adviser, sponsor, administrator or in other capacities. Stephens or its affiliates typically receive fees for services provided to such Funds, which often include (but are not limited to) fees payable under a plan adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (“12b-1 fees”) and fees paid to compensate Stephens for providing administrative services, distribution services, shareholder services, investment advisory services or other services to or for the benefit of such Funds. Stephens Inc. as a dually-registered broker-dealer is paid the retail 12b-1 fees for brokerage mutual fund investments. Where 12b-1 fees are received in advisory accounts, these fees are rebated to the client account. b) From time to time, client account assets are invested in transactions that involve or constitute a purchase, sale or other dealings with securities or other instruments for which (i) Stephens, (ii) an affiliate or employee of Stephens, (iii) an entity in which Stephens or an affiliate has a direct or indirect interest, or (iv) another member of a syndicate or other intermediary (where an entity referred to in (i), (ii), or (iii), above is or was a member of the syndicate), has acted, now acts, or in the future may act as an underwriter, syndicate member, market maker, dealer, broker, principal, agent, research analyst or in any other similar capacity, whether the purchase, sale or dealing occurs during the life of the syndicate or after the close of the syndicate. Stephens has an incentive to favor the securities of issuers for which it provides such services. Your IAR also receives more money if you buy these investments. c) Stephens or any other broker-dealer that is or may become affiliated with Stephens (the “affiliated brokers”) is expected to act as broker or dealer to execute transactions on behalf of a client’s account. Client will not be charged a separate fee for brokerage services provided to the Account by affiliated brokers. d) Stephens or its affiliates sometimes effect transactions for the client’s account with other accounts for which Stephens or an affiliate provides investment advisory services ADV Part 2A Appendix 1 March 31, 2025 20  (“Cross Trades”). Such Cross Trades are intended to enable Stephens to purchase or sell a block of securities at a set price and possibly avoid an unfavorable price movement that may be created through entrance into the market with such purchase or sell order. Stephens typically receives compensation from other accounts involved in a Cross Trade. e) Subject to applicable regulations, Stephens or its affiliates sometimes execute “Agency Cross Transactions” for the client’s account. Agency Cross Transactions are transactions where Stephens, or any affiliate of Stephens, acts as broker for both the client’s account and the other party to the transaction. In such transactions, Stephens, or any of Stephens’ affiliates acting as broker, receives commissions from the other party to such transaction, to the extent permitted by law, in addition to its customary investment management or advisory fee for the client’s account. f) Clients of other divisions of Stephens or clients of other advisory representatives of Stephens or Stephens, its principals, employees, affiliates and their family members, sometimes hold, and sometimes engage in transactions in, securities purchased or sold for the client or about which Stephens gives or has given client advice. The client’s account may purchase as investments securities of companies with which Stephens or its affiliates maintain investment banking relationships or other relationships or securities of companies in which Stephens or its affiliates have an ownership or other investment interest. g) Subject to applicable law, Stephens sometimes pays fees to, and/or shares revenues with, affiliates or non-affiliates in connection with referrals for investment advisory accounts. For additional information regarding referral fees, please see Item 9. h) Stephens, or its affiliates, may provide more than one type of service to the client (or a related organization), including (but not limited to), investment management services, investment advisory services, financial advisory services, underwriting services, placement agency services, investment banking services, securities brokerage services, securities custodial services, insurance agency services, insurance brokerage services, administrative services or other services, or any combination of services, all on such terms as may be agreed between Stephens (or its affiliate) and client (or its related organization). i) Other divisions and other advisory representatives of Stephens perform investment advisory services for the clients other than client and such other divisions or other advisory representatives of Stephens give advice or take action with respect to other clients that are similar to or different from the advice given or action taken for the client’s account, in terms of securities, timing, nature of transactions and other factors. Stephens will, to the extent practicable, attempt in good faith to allocate investment opportunities among its clients, including the client, on a fair and equitable basis. However, other divisions and other advisory representatives of Stephens will not undertake to make any recommendation or communication to client with respect to any security which such other divisions or advisory representatives may purchase or sell ADV Part 2A Appendix 1 March 31, 2025 21  (either as principal or for any other client’s account) or recommend to any other client, or in which such other divisions or advisory representatives, or their respective principals, employees, affiliates or their family members, may engage in transactions. j) For ERISA accounts, when Stephens provides non-discretionary investment advice to the client regarding such an account, we are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we are compensated can create conflicts of interest, so we have established procedures which require us to act in the client’s best interest and not put our interest ahead of the client’s. Performance-Based Fees and Side-By-Side Management In the SC program Stephens does not offer any performance-based fee alternatives. Stephens typically charges clients an investment advisory fee based on the value of the assets in the client’s account. All fees are negotiable and vary depending on the size of the investment, the nature of the services to be rendered by Stephens to the client, and other factors. Performance fees are typically invoiced annually. Methods of Analysis, Investment Strategies and Risk of Loss We utilize street and independent sources for our research, but it is not the sole basis of our investment decision making process. Other sources of information we utilize can include industry data obtained from subscription services, company filings, street research and models. We utilize these services for real-time news and pricing. We also utilize other independent research sources for quantitative reports that measure such things as price changes, growth rates, profitability, valuation, earnings surprises and earnings revisions. These quantitative reports are used to help identify new securities that meet our investment criteria and to monitor existing holdings. Investing in securities involves risk of loss that clients should be prepared to bear. The material risks associated with our strategies are: Debt Obligations -- Investing in debt (bond) obligations entails additional risks, including interest rate risk such that when interest rates rise, the prices of bonds and the value of bond funds shares can decrease and the investor can lose principal value. Equity Market Risk – Overall stock market risks affect the value of the investments in equity strategies. Factors such as U.S. economic growth and market conditions, interest rates, and political events affect the equity markets. Foreign Debt Obligations - Investing in foreign debt obligations entails additional risks, including those related to regulatory, market or economic developments, foreign taxation and less stringent investor protection and disclosure standards. ADV Part 2A Appendix 1 March 31, 2025 22  Foreign Securities - Investing in foreign securities presents certain risks that are not present in domestic securities. For example, investments in foreign and emerging markets present special risks including currency fluctuation, the potential for diplomatic and political instability, regulatory and liquidity risks, foreign taxation and differences in auditing and other financial standards. In addition to the greater exposure to the risks of foreign investing, emerging markets present considerable additional risks, including potential instability of emerging market countries and the increased susceptibility of emerging market economies to financial, economic and market events. Money Market Risk - An investment in a Money Market Fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although the fund seeks to preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in the fund. Yields will vary. Yield quotations more closely reflect the current earnings of the fund than the total return. Management Risk - Our judgments about the attractiveness and potential appreciation of a particular asset class, mutual fund or individual security may be incorrect and there is no guarantee that individual securities will perform as anticipated. The price of an individual security can be more volatile than the market as a whole and our investment thesis on a particular stock may fail to produce the intended results. Small Cap and Mid Cap Company Risk - Investing in small cap and mid cap issuers involves a significantly greater risk than investing in larger, more established companies. The daily trading volume for Small Cap and Mid Cap issuers can be much lower than for more widely held, established companies. There may be periods when it is difficult to invest in or liquidate portfolio investments for our various investment strategies. This is particularly the case when breaking news on a company occurs or when significant market forces and events occur. In addition, small and mid-cap companies are more vulnerable to economic, market and industry changes. Because smaller companies often have limited product lines, markets or financial resources, or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than larger capitalization companies. Investors should only invest a portion of their total portfolios in these securities, and investors should be prepared to lose their entire investments. Certain Risks Associated with Cybersecurity. With the increased use of technologies such as the Internet to conduct business, investment advisers, including Stephens rely in part on digital and network technologies (collectively, “cyber networks”). These cyber networks are susceptible to operational, information security and related risks and can be at risk of cyber-attacks. Cyber-attacks could seek unauthorized access to cyber networks for the purpose of misappropriating sensitive information, corrupting data, or causing operational disruptions. Cyber-attacks can potentially be carried out against the issuers of securities you have invested in, against third party service providers, or against Stephens itself by persons using ADV Part 2A Appendix 1 March 31, 2025 23  techniques that range from efforts to circumvent network security, overwhelm websites, and gather intelligence through the use of social media in order to obtain information necessary to gain access to cyber networks. Although cyber-attacks potentially could occur, Stephens and Pershing maintains an information technology security policy and technical and physical safeguards intended to protect the confidentiality of internal data. Policies and Procedures for Proxy Voting For proxy voting directed by Stephens, it is Stephens’ policy to vote proxies on securities that are owned in an account and held in custody for the account at Pershing for the account and to utilize Investment Advisory policies and procedures, which are reasonably designed to vote client securities in the best interests of the client and to address how potential conflicts of interest are handled. Stephens’ proxy voting policy is to vote in favor of actions recommended by the issuer’s Board of Directors, unless the advisory representative disagrees with the proposed action and elects to vote the shares against the recommendation of the Board of Directors. If there is not a Board of Directors recommendation on a proposed action, then the advisory representative will determine whether to vote for, against or abstain. If the Client chooses to have their securities custodied away from Pershing, it will be the responsibility of the client to vote or to arrange for the voting of their proxies. Stephens will make available information of the firm’s proxy voting policy and procedures including information regarding how Stephens voted proxies, if requested. In response to any request as to how the client’s proxies were voted, the Chief Compliance Officer or his designee would provide the information to the client. Procedure Stephens’ procedures to implement the Firm’s proxy voting policy, is as follows: in Stephens’ • Proxy materials are received on behalf of clients Reorganization Department (“Reorg. Department”); • • A Proxy Voting Notice, which includes a link to the proxy voting materials, is sent by the Reorg Department via e-mail to the respective advisory area. This Proxy Voting Notice will be used to instruct the Reorg Department as to how to vote the shares; Stephens will vote the proxy through the Reorg Department in accordance with applicable voting guidelines, either by electronically voting or by mailing the proxy in a timely and appropriate manner; • Unless the responsible advisor or advisory committee loses confidence in management of the issuer or the client directs the vote, Stephens will vote the shares as recommended by the Board of Directors of the issuer; If there is not a Board of Director’s recommendation on a proposed action, then the advisory representative will determine whether to vote for, against or abstain. ADV Part 2A Appendix 1 March 31, 2025 24  Conflicts of Interest On an annual basis, Stephens will disclose to affected client any identified potential material conflicts of interest by providing a list of said conflicts electronically or by mail. Where Stephens has identified a specific potential material conflict of interest relating to one or more matters to be voted on by shareholders, Stephens: (1) will notify affected clients of the potential conflict of interest, (2) will disclose how the proxy will be voted absent a voting direction from the client, and (3) will give affected clients the opportunity to vote the proxy themselves. Stephens will maintain a record of the voting resolution of any conflict of interest. Corporate Actions and Other Matters From time to time there may also be a variety of corporate actions or other matters for which shareholder action is required or solicited and with respect to which Stephens may take action that it deems appropriate in its best judgment except to the extent otherwise required by agreement with the client. These actions include, for example and without limitation, responding to tender offers or exchange offers, bankruptcy proceedings and proposed class action settlements. However, Stephens will have no power, authority, responsibility or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in the client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. Item 7 Client Information Provided to Portfolio Managers The SC Program is a platform designed by Stephens to assist qualified retirement plans or other deferred compensation programs with establishing an appropriate line-up of “no load” or “load waived” mutual funds chosen through Stephens’ process of selection of mutual funds representing a range of designated asset classes to achieve appropriate asset allocation portfolios for the investment of plan assets. Portfolios in this platform are managed and directed by the Plan Sponsor and/or Plan Trustee or the Plan participants and not by a separate portfolio manager. An Agreement is completed for each Plan account that has active trading at Stephens, and maintained by Stephens. If, the account is custodied at Pershing, the account application will be signed by the advisory client. The account application contains account name and address, investment objectives and specific financial information. Advisory account information is updated upon notification from the advisory client of any material changes and noted within the customer file. The IAR assigned to manage the account has access to the client’s data maintained by Stephens. Client information may be updated from time to time upon notification from the Plan Sponsor and/or Plan Trustee of any material changes and noted within the Plan’s file. ADV Part 2A Appendix 1 March 31, 2025 25  We reserve the right to accept or decline any account and in accordance with the terms of a particular account’s investment agreement, we reserve the right to close an account if appropriate in our discretion. Item 8 Client Contact with Portfolio Managers Client Meetings The IAR assigned to a client’s account will be the primary contact for the client at Stephens. The IAR must offer or per client’s request, to meet with clients periodically to discuss their investment portfolios and investment goals, but not less frequently than annually. Clients are encouraged to contact the Stephens IAR assigned to their account at any time if the client would like to have additional discussions or meetings. Item 9 Additional Information Disciplinary Information Stephens Inc. voluntarily participated in the Securities and Exchange Commission’s Share Class Selection Disclosure Initiative, and on March 11, 2019 the SEC entered a Cease and Desist Order against Stephens in which Stephens neither admitted nor denied the allegations of the SEC’s Order. The Order alleged that Stephens did not fully disclose conflicts of interest related to the selection of mutual fund share classes for its advisory clients, and that Stephens purchased, recommended or held mutual fund share classes for client accounts which paid Stephens 12b-1 fees when less expensive share classes of the same funds were available which did not pay Stephens these 12b-1 fees. The Order directed Stephens to Cease and Desist from committing or causing any violations and any future violations of Sections 206(2) and 207 of the Investment Advisers Act of 1940 and ordered that Stephens be censured and pay disgorgement and prejudgment interest to advisory clients who held these more expensive mutual funds share classes in their advisory accounts. (IA Release No. 40-5196) In its capacity as a broker-dealer, Stephens has been subject to legal or disciplinary events in the ordinary course of its business, such as regulatory sanctions relating to compliance with broker-dealer trade reporting requirements and other regulatory actions. Affiliations Stephens, from time to time, enters into arrangement with other broker-dealers, investment advisors or other persons whereby such parties refer clients seeking advisory services to Stephens. For additional information regarding Stephens’ affiliations, please see Item 6 “Conflicts of Interest” above. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ADV Part 2A Appendix 1 March 31, 2025 26  Investment Advisory Code of Ethics Stephens has adopted an Investment Advisory Code of Ethics (“Code”), which defines the requirements and expectations for the business conduct of all of its Investment Advisory employees, including employees of Stephens. Furthermore, all Stephens employees are expected to adhere to Stephens’ Mission and Values Statement and Code of Professional Conduct. The fundamental position of Stephens is that all aspects of its business are to be conducted in an ethical and legal manner in accordance with federal law and the laws of all states where the investment advisory divisions do business. In accordance with that position, general principles apply: 1. The interests of Stephens’ clients are our first consideration. Any personal securities transaction, which would be detrimental or potentially detrimental to any client account and any personal securities transaction, which is designed to profit by the market effect of any client account, must be avoided. 2. All personal securities transactions should be conducted in such a manner as to be consistent with the Code and to avoid actual or potential conflicts of interest or abuse of a Stephens employee’s knowledge of customer information or customer transactions. 3. Investment adviser personnel should not take inappropriate advantage of their positions. Information concerning the identity of security holdings and financial circumstances of clients is confidential. 4. Independence in the investment decision-making process is paramount. Accordingly, there are certain standards of conduct, which Stephens investment advisory employees follow to reduce potential conflicts with the interests of our clients. Stephens will provide a copy of the Code to any client or prospective client upon request. Stephens Personal Trading Stephens’ personnel may not participate in initial public offerings. All employees are required to maintain their personal accounts and accounts in which they have a beneficial interest at Stephens unless the account has been specifically exempt in writing from this requirement. Stephens’ employees are required to provide copies of all of their trade confirmations and brokerage account statements to Stephens’ Compliance Department in order to permit the monitoring of compliance with personal trading policies and restrictions. Additionally, employees are required to report all personal securities transactions no less than quarterly. Stephens’ Investment Advisory Code of Ethics (the “Code”) requires employees to report violations of the Code to Stephens’ Chief Compliance Officer. Conflict of Interest with Personal Trading and Client Trades To minimize potential conflicts of interest, advisory personnel who determine or approve what recommendations will be made for client accounts will not participate in Stephens’ ADV Part 2A Appendix 1 March 31, 2025 27  proprietary trading activities and will not know what trading strategies are employed for its proprietary accounts. Stephens allows employees to make purchases in the marketplace of securities owned by any client account, provided that such purchases are made in amounts consistent with the normal investment practice of the person involved. Such purchases must be made after the investment advisory accounts managed by such employee (or in the management of which such employee participates) has completed its transactions in such securities. Under certain circumstances, employee transactions may be permitted prior to full completion of investment advisory division’s transactions. Such exceptions require prior approval of the appropriate Preclearance Officer and will only be granted after considering factors such as the time element involved in filling the order, market considerations, etc. Client Referrals and Other Compensation Neither Stephens nor any of our employees receives any sales awards or other prizes from any non-affiliated outside parties for providing investment advice to our clients. Stephens may enter into referral arrangement with its affiliates or between divisions of the Firm. This includes referrals to Stephens of prospective clients seeking investment advisory services. If the referral results in a new account relationship, then a portion of the net revenue from such account is paid to such entity or division as a referral fee, and such entity or division may pay some portion of the fee to the referring person. This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. Such arrangements are conducted in accordance with the Marketing Rule, as applicable, and the Advisers Act generally. IARs are eligible to receive referral fees for referring eligible clients to the Stephens Investment Banking division. For eligible investment banking referrals, referring parties are eligible to receive compensation as a percentage of net income earned by Investment Banking. Therefore, IARs are incentivized to refer clients to the Investment Banking division. Any such compensation to the IAR is at the discretion of the Firm. Supervision and Review of Accounts The StephensChoice Investment Committee responsibilities are to select, monitor and review mutual funds included on the SC platform, establish standard SC model asset allocations, monitor performance of SC mutual funds and asset allocation models and to make changes or adjustments from time to time to the line-up of mutual funds included in the SC program including adjustments to the standard SC asset allocation models. Supervisory Principals are responsible for supervisory approval of new advisory accounts, the daily review of trading activity and periodic reviews of performance utilizing various other daily and monthly exception reports. Supervisory Principals may also consider levels of activity, timing of transactions, transactions in restricted securities, profitability, concentration in one security and individual objectives and needs of the client based on information provided by the client. In addition to the monthly reviews, designated principals at Stephens’ home office make quarterly reviews of the investment performance ADV Part 2A Appendix 1 March 31, 2025 28  and investment strategy of selected accounts. The reviewers may refer accounts to the Compliance Department for further analysis if necessary. When Stephens executes a transaction for you through Pershing’s order execution system, you will receive a written or electronic confirmation of the transaction which provides information regarding the transaction. You may elect to receive these quarterly. You will also receive a written or electronic monthly account statement if you had activity in your account during the month which will detail the activity and the positions in your account. If you have not had any activity during the quarter and you have positions in your account, you will receive a written or electronic quarterly account statement which details the positions in your account. You may waive the receipt of account statements or confirmations after each trade in favor of e-delivery via https://stephensaccess.netxinvestor.com/web/stephens/login . You may also receive mutual fund prospectuses, where appropriate. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b-1 fees are received on client holdings, these will be rebated to the advisory client. Financial Information Stephens does not require or solicit prepayment of more than $1200 in fees per client six months or more in advance and, thus, has not included a balance sheet of its most recent fiscal year. Stephens is not aware of any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to our clients. Who to Contact We are pleased to have an opportunity to serve as your investment adviser. If you have any questions about the information contained in this brochure or about any aspect of the services we provide, please do not hesitate to call Stephens at (877-891-0095). Clients often receive this information by electronic delivery. Stephens ADV and additional brochures are The available at www.stephens.com/investment-disclosures/. To access your IAR's SEC Advisor Biography, go to www.stephens.com , use the search bar in the top right corner of the home page and search by your IAR's name. SEC Advisor Biographies are also available in the "Our Team" section and are there for your review. ADV Part 2A Appendix 1 March 31, 2025 29  Definitions and Professional Designation Qualifications Accredited Investment Fiduciary® (AIF®) The Accredited Investment Fiduciary (AIF®) Designation is a professional certification that demonstrates an advisor or other person serving as an investment fiduciary has met certain requirements to earn and maintain the credential. The purpose of the Accredited Investment Fiduciary (AIF®) Designation is to assure that those responsible for managing or advising on investor assets have a fundamental understanding of the principles of fiduciary duty, the standards of conduct for acting as a fiduciary, and a process for carrying out fiduciary responsibility. The AIF® training curriculum is offered in distance education or a blended learning option to suit each Candidate's needs. Fi360’s Prudent Investment Practices cover four Steps (domains), twenty-one Practices (tasks), and seventy-nine Criteria that an investment fiduciary is expected to be able to perform. After passing the exam, a Candidate wishing to file for the AIF® designation must submit the accreditation application and accreditation fee. Six Hours of annual continuing education is required, a minimum of four of which must be delivered by Fi360 or one of Fi360's approved CE providers. Accredited Wealth Management AdvisorSM (AWMA® ) Individuals who hold the AWMA® designation have completed a course of study encompassing wealth strategies, equity-based compensation plans, tax reduction alternatives, and asset protection alternatives. Additionally, individuals must pass an end- of-course examination that tests their ability to synthesize complex concepts and apply theoretical concepts to real-life situations. All designees have agreed to adhere to Standards of Professional Conduct and are subject to a disciplinary process. Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standards of Professional Conduct and complying with self-disclosure requirements. The Chartered Financial Analyst (CFA) The CFA Institute is an international non-profit organization whose stated mission is to promote and develop a high level of educational, ethical and professional standards in the investment industry. To be eligible for the CFA designation, candidates must pass 3 examinations that test the academic portion of the CFA program, possess a bachelor’s degree from an accredited educational institution or equivalent, and have 48 months of acceptable professional work experience. The CFA curriculum includes the following subject areas: Ethical and Professional Standards; Quantitative Methods (such as the time value of money, and statistical inference); Economics; Financial Reporting and Analysis; Corporate Finance; Analysis of Investments (such as stocks and bonds); and Portfolio Management and Analysis (asset allocation, portfolio risk, and performance measurement). CERTIFIED FINANCIAL PLANNER™ (CFP®) To earn the CFP® designation, an individual must complete a college-level course of study addressing the financial planning subject areas determined by the Certified Financial Planner Board of Standards, Inc. (“CFP Board”), pass a comprehensive two-day ADV Part 2A Appendix 1 March 31, 2025 30  examination developed by the CFP Board and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university) and demonstrate three years of full-time work experience in financial planning or a related field. CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning. CFP®s are require to complete 30 credit hours of continuing education accepted by CFP Board every to two years, including 2 hours of CFP Board-approved Ethics CE. Chartered Financial Consultant® (ChFC®) The ChFC® Program offers comprehensive education in the essentials of financial planning, including insurance, taxation, retirement, and estate planning. It also addresses advanced areas such as behavioral finance, non-traditional family structures, and small business planning. There are no prerequisite courses required before you can begin the ChFC® Program, but to use the designation, you are required to have three years of full-time, relevant business experience and a high school diploma or the equivalent. To receive and maintain the ChFC® designation, you must agree to comply with The American College Code of Ethics and Procedures and participate in the annual Professional Recertification Program (PRP) to maintain the designation. Certified Investment Management Analyst (CIMA) The CIMA certification signifies that an individual has met initial and on-going experience, ethical, education, and examination requirements for investment management consulting, including advanced investment management theory and application. Prerequisites for the CIMA certification are three years of financial services experience and an acceptable regulatory history. To obtain the CIMA certification, candidates must pass an online Certification Examination. The Certification Examination is a five-hour examination and has 125 multiple-choice questions and 15 non-scored, pretest questions. Each examination item (question) is related to an area of work performed by an investment management consultant/advisor. The topics have been identified through a job analysis. All examination items are written in a four-option, multiple-choice format. CIMA designees are required to adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and Guidelines for Use of the Marks. CIMA designees must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through Investment Management Consultants Association (IMCA). Certified Pension Consultant (CPC) The Certified Pension Consultant (CPC) credential is conferred by ASPPA to benefits professionals working in plan administration, pension actuarial administration, insurance and financial planning. CPCs work alongside employers to formulate, implement, administer and maintain qualified retirement plans. The CPC is the capstone credential, or highest credential, currently conferred by ASPPA. ADV Part 2A Appendix 1 March 31, 2025 31  To earn the CPC credential, you must successful complete various exams, verify a minimum of two years’ experience in the retirement plan industry, provide two letters of recommendation and apply for the ASPPA credentialed membership. All credentialed members must acquire 40 hours of continuing education (CE) credits (2 of which must be Ethics) in a two-year cycle and renew their ASPPA Membership annually to retain their credential(s). The Certified Portfolio Manager (CPM®) The Certified Portfolio Manager (CPM®) designation is a collaboration of the Academy of Certified Portfolio Managers and Columbia University. The academic component is designed to provide a deeper understanding of fundamental security analysis, asset allocation, and portfolio management concepts for financial services industry professionals managing discretionary portfolios. The curriculum encompasses eight core concepts: • Quantitative Methods • Financial Statement Analysis • Corporate Finance • Fixed Income Analysis • Equity Analysis • Fiduciary Responsibility • Derivatives Qualifying for the CPM® designation The current criteria for applicant eligibility are any of the following (1) A certificate, diploma or academic degree providing evidence of a four-year undergraduate degree.(2) 3 years of employment in the financial services industry and (3) Letter of recommendation on behalf of the applicant who is employed in the financial services industry, written by a supervisor, where the credential requirements are desired for the training and development of the applicant. At the end of each calendar year, ACPM members are required to submit the following; Record of 20 completed continuing education hours. ACPM maintains a self-auditing continuing education policy. Answers to a series of Professional Conduct questions. Annual membership dues. All three items are due by December 31st of that calendar year. Certified Public Accountant (CPA) CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally include minimum college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting), minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA), and successful passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of continuing professional education ADV Part 2A Appendix 1 March 31, 2025 32  (CPE) activities on an ongoing basis. Additionally, all American Institute of Certified Public Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct. Chartered Retirement Planning Counselor SM (CRPC®) The CRPC® is conferred by the College for Financial Planning. Individuals who hold the CRPC® designation have completed a course of study encompassing pre-and post- retirement needs, asset management, estate planning and the entire retirement planning process using models and techniques from real client situations. Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standard of Professional Conduct and complying with self-disclosure requirements. Chartered Retirement Planning Specialist SM (CRPS®) The CRPS® is conferred by the College for Financial Planning. Individuals who hold the CRPS® designation have completed a course of study encompassing the specialization in creating, implementing and maintaining retirement plans for businesses. They must pass an exam demonstrating their expertise. Successful applicants earn the right to use the CRPS designation with their names for two years. Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standard of Professional Conduct and complying with self-disclosure requirements. Qualified Plan Financial Consultant (QPFC) QPFC is the professional credential for financial professionals who sell, advise, market or support qualified retirement plans. The QPFC program provides an understanding of general retirement planning concepts, terminology, distinctive features of qualified plans and the role of retirement plan professionals. QPFC is for professionals with two to three years of retirement plan experience. A candidate will be expected to demonstrate a general proficiency of plan administration, compliance, investment, fiduciary, and ethics issues. In order to obtain the QPFC credential, individuals must pass the CPFA®/QPFC exam, agree to abide by the ARA Code of Professional Conduct, and apply for the credential. QPFC credentialed members must acquire 10 hours of Continuing Education (CE) credits (1 of these must be Ethics) annually and renew NAPA Membership annually to retain credentials. ADV Part 2A Appendix 1 March 31, 2025 33 

Uniform Application for Investment Advisor Registration Stephens Inc. 111 Center Street Little Rock, AR72201-4430 877-891-0095 Website: www.stephens.com Stephens Capital Management (“SCM”) Programs Stephens Capital Management Discretionary Stephens Capital Management Fixed Income Stephens Spectrum Program Stephens Spectrum 401K Program Stephens Capital Management Non-Discretionary Pension Management Trust Program Health Management Trust Program Stephens IA Consulting March 31, 2025 This wrap fee program brochure provides information about the qualifications and business practices of Stephens Inc. If you have any questions about the contents of this brochure, please contact us at 877-891-0095 or www.stephens.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Stephens Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. Stephens Inc. is a registered investment adviser with the United States Securities and Exchange Commission. Registration does not imply a certain level of skill or training. SEC File No: 801-15510 ADV Part 2A Appendix 1 March 31, 2025 1  Item 2: Material Changes This is an annual update to the Stephens Capital Management wrap fee program brochure. This section identifies and discusses material changes since the last annual update dated March 28, 2024. For more details, please see the item in this brochure referred to in the summary below. Item 9 was updated to disclose: (i) payments employees of Stephens Inc. and its affiliates can receive for referring prospective clients seeking investment advisory services, and (ii) payments Financial Consultants and Investment Advisor Representatives are eligible to receive for making referrals to Stephens Inc.’s Investment Banking division. ADV Part 2A Appendix 1 March 31, 2025 2  Item 3 Table of Contents Item 2: Material Changes ............................................................................................................................................................. 2 Item 3 Table of Contents .............................................................................................................................................................. 3 Item 4: Services, Fees and Compensation .................................................................................................................................... 4 General Information on Services and Fees................................................................................................................................................................. 4 General Description of Programs and Services ............................................................................................................................. 6 Stephens Capital Management Discretionary Programs ............................................................................................................................................ 7 Stephens Capital Management Advisory Services for Employee Benefit Plans ......................................................................................................... 9 Comparing Costs ...................................................................................................................................................................................................... 10 Additional Fees ......................................................................................................................................................................................................... 11 Compensation to the Investment Adviser Representative ...................................................................................................................................... 17 Item 5: Account Requirements and Types of Clients ................................................................................................................... 17 Account Minimums .................................................................................................................................................................................................. 17 Types of Clients ........................................................................................................................................................................................................ 17 Item 6: Portfolio Manager Selection and Evaluation ................................................................................................................... 17 Selection and Review of Portfolio Managers ........................................................................................................................................................... 17 Review of Portfolio and Performance ...................................................................................................................................................................... 17 Conflicts of Interest .................................................................................................................................................................................................. 18 Portfolio Management Description of Advisory Services ......................................................................................................................................... 22 IARs or Stephens Acting as Portfolio Manager ......................................................................................................................................................... 26 Investment Advisory Proxy Policies .......................................................................................................................................................................... 26 Item 7: Client Information Provided to IARs and Sub-Advisors.................................................................................................... 28 Item 8: Client Contact with IARs .................................................................................................................................................. 28 Client Meetings ........................................................................................................................................................................................................ 28 Item 9: Additional Information ................................................................................................................................................... 28 Disciplinary Information ........................................................................................................................................................................................... 28 Affiliations ................................................................................................................................................................................................................ 28 Code of Ethics ........................................................................................................................................................................................................... 28 Review of Accounts .................................................................................................................................................................................................. 29 Client Referrals and Other Compensation ............................................................................................................................................................... 29 Financial Information ............................................................................................................................................................................................... 30 Who to Contact ........................................................................................................................................................................................................ 30 Definitions and Professional Designation Qualifications ............................................................................................................. 31 ADV Part 2A Appendix 1 March 31, 2025 3  Item 4: Services, Fees and Compensation Stephens Inc. ("Stephens") is an Arkansas corporation, which registered with the Securities and Exchange Commission (“SEC”) as a broker-dealer in September 1946. Stephens registered as an investment advisor with the SEC on September 19, 1980 and began providing investment advisory services at that time. Stephens is a full service broker-dealer and investment bank. In addition to being registered with the SEC, Stephens is a member of the Financial Industry Regulatory Authority (“FINRA”), the New York Stock Exchange, Inc. (“NYSE”), the NYSE American LLC (“NYSE-AMEX”), the Municipal Securities Rulemaking Board (“MSRB”), the Investors’ Exchange LLC (“IEX”) and the Securities Investor Protection Corporation (“SIPC”). Stephens derives greater revenues from its broker-dealer and investment banking activities than it derives from its investment advisor activities. Affiliates of Stephens are also separately engaged in financial services businesses, including merchant banking, insurance and investment advisory businesses. General Information on Services and Fees Investment Advisory Agreement Entering into an advisory relationship with Stephens involves the execution of an Investment Advisory Agreement (“Advisory Agreement” or “Agreement”). The term of the Agreement is generally for a period of one year beginning on the effective date of the Agreement, and is automatically renewed for successive additional one-year terms without further action. At the time of entering into such Agreement, the client has a right to terminate the Agreement without penalty within five (5) business days after the entering into the Agreement and receive a full refund of any investment advisory fees paid to Stephens. At any time, either the client or Stephens may terminate the Agreement without penalty, upon ten (10) days’ notice given in writing to the other party hereto. If the account is to be liquidated as the result of a termination notice, it is understood that Stephens may take up to five (5) trading days to effect liquidation following the date the liquidation request was received by Stephens. Proceeds will be payable to the client within ten (10) business days of termination. Upon termination of the Agreement and payment of all sums which may be owed under the Agreement, Stephens shall make such disposition of the managed securities or other property of the client held by it as may be directed by the client. The client will agree to pay Stephens the reasonable fees, costs and expenses incurred for such disposition and for collection, including attorney fees, of any unpaid balances under the Agreement. At any time the client can terminate its Agreement upon the terms without penalty. On June 5, 2019, the Securities and Exchange Commission issued its interpretation of the Standard of Conduct for Investment Advisers and rescinded certain previously issued no action letters. As a result of these changes, Stephens will not seek to enforce any provision of an investment advisory agreement with a retail investor which discharges Stephens or its agents from liability to the retail investor client. Termination of Agreement Termination of the Agreement will not affect the liabilities or obligations of the parties arising from transactions initiated prior to termination. However, as discussed above, fees are payable in arrears and will be prorated in the event of termination of the Agreement. Either Stephens or the client may terminate the Advisory Agreement or may terminate an account managed pursuant to the Advisory Agreement. Upon termination of the Advisory Agreement, Stephens will convert your mutual funds to a non-advisory share class. Please review the section of this Brochure entitled “Funds in Advisory Programs.” Termination of Retirement Account Agreements Either Stephens or the client may terminate the Advisory Agreement or may terminate an account managed pursuant to the Advisory Agreement. Retirement accounts can be terminated by the client by simultaneously, (1) providing written notice of termination to Stephens and (2) providing Stephens with transfer instructions for the account to another custodian or instructions to distribute the account assets. Distribution of account assets can create tax consequences. Termination of the Advisory Agreement does not affect the liabilities or obligations of the parties arising from transactions initiated prior to termination. Fees You pay a single asset-based fee, charged on a quarterly basis, which covers the services provided by Stephens. ADV Part 2A Appendix 1 March 31, 2025 4  Advisory fees apply to standard accounts and include management, brokerage services, custodial services, associated accounting reports and investment management reports. This is a wrap fee. Fees are negotiable in special circumstances based on a number of factors including the type and size of the account and the range of services provided by the Investment Advisor Representative (“IAR”). In special circumstances, and with your agreement, the fee charged to you for an account may be more than the maximum annual fee stated in this section. When Fees are Paid and How Fees are Computed The fee for the period from the date assets are first credited to the account to the end of the then-current calendar quarter shall be determined by computing the average market value of cash and securities in the portfolio as of the close of business on the last day of each calendar month (that ends on or after the date assets are first credited to the account referred to above), and multiplying the resultant average market value by one-fourth of the applicable annual fee rate(s) indicated above, pro-rated for the percentage of the current calendar quarter during which the portfolio is under management. The fee for any subsequent calendar quarter shall be determined by computing the average market value of cash and securities in the portfolio as of the close of business on the last day of each calendar month, and multiplying the resultant average market value by one-fourth of the applicable annual fee rate(s) indicated above. If an account has a margin debit balance, the market value of the account used in computing Stephens’ fee is the total market value of all eligible assets, and it is not reduced by the margin debit balance. For example, an account with a total market value of $120,000 and a margin debit balance of $20,000 will have a net market value of $100,000. Stephens’ fee would be computed using the total market value of $120,000 times 1/4th of the applicable annual fee rate(s) adjusted by the time period. In the event a client’s account is closed between quarter-ends, fees will be prorated as of the date of termination. The fee is deducted from the client’s account quarterly in arrears unless otherwise agreed in writing. Investment advisory clients have the option to seek execution of transactions recommended by SCM through broker- dealers other than Stephens. However, on transactions executed through Stephens with Pershing, Stephens or Pershing will not charge a commission to the client except when shares of an underwriting issue in which Stephens is in the syndicate are purchased for the account, in which case the sales and underwriting fees are built into the offering price. For accounts invested entirely or partially in an equity strategy, please review sections of this Brochure entitled “Additional Compensation to Stephens.” For the duration of this Agreement, a portion of the fees you pay in connection with the account may be paid to your IAR and other employees of Stephens and its affiliates. Stephens may, in its sole discretion, pay all or a portion of the fees to other parties involved in providing services with respect to client account(s) and as permitted by law. No party shall be compensated based on a share of capital gains or capital appreciation of funds or any portion of funds or other investments in the account. In addition to the wrap fee the client may also incur certain charges, including among others the following types of charges: other transaction charges, service fees, wire fees and Individual Retirement Account (“IRA”) and Qualified Retirement Plan fees. Other parties receive a portion of these third-party fees. Further information regarding charges and fees assessed by other securities sponsors or Sub-Advisors is available in their appropriate ADV. Additional Fees Mutual Funds For any mutual fund investments Stephens’ clients invest in, fees are also charged by the mutual fund, as more fully described in the mutual fund’s prospectus. In discretionary accounts, Stephens has discretion to invest client funds in investment company securities in many of its advisory accounts. Individual mutual funds also pay fees to Stephens, via Pershing, as a result of these investments. 12b-1 fees are rebated back to the advisory account. The existence of such applicable fees is disclosed in the client Advisory Agreement and such fees are more fully described in the fund prospectuses delivered to each client on initial investment. Is a Wrap Fee Arrangement for you? In Stephens SCM wrap fee programs, the client pays a single fee for investment advisory services and related services, which may include executions, custody, and clearing charges. Such wrap fee programs may cost the client more or less ADV Part 2A Appendix 1 March 31, 2025 5  than purchasing such services separately depending upon such factors as trading activity, account size and account minimums for non-wrap accounts. We encourage you to carefully consider your options in establishing or maintaining an advisory fee-based account. As a general matter, a fee-based advisory account approach may be considered appropriate for clients who rely on investment advice or investment management services or who engage in moderate to high levels of trading activity. A fee-based approach can be more economical for clients who engage in active trading, since the price per trade is reduced as the number of trades increases under a fee-based approach. However, fee-based advisory account arrangements may not be appropriate for clients who rely primarily on their own independent resources and judgments for making their investment selections and decisions and do not wish to purchase advisory services. Clients who engage in a lower level of trading activity might prefer a traditional brokerage account with a commission payable on each transaction, particularly if the client typically does not utilize advisory services for trading decisions, as transaction cost savings might be realized in the context of a traditional pay-per-trade commission structure. However, retirement accounts are not available through Stephens as brokerage accounts. Typically, a portion of any revenue that the firm realizes in connection with an advisory account will be included in the calculation of the compensation to be paid by the firm to the IAR; and, therefore, the IAR will experience conflicts of interest similar to those experienced by the firm. Account Review The IAR assigned to your account is your primary point of contact with Stephens. Your IAR should offer to discuss or meet no less frequently than annually with you as an advisory client. Stephens encourages you to contact your IAR at any time if you have questions or would like to have additional discussions or meetings. If you have experienced any changes regarding your finances, investment objectives or risk tolerance, please contact your IAR to see if any adjustments are necessary to your investment strategy. statements or trade in favor of e-delivery Confirmations, Account Statements and Performance Reviews In most cases, Pershing LLC (“Pershing”) is the custodian of your account and provides you with written or electronic confirmation of securities transactions, and account statements at least quarterly. You will also receive a monthly account statement if you have had qualifying activity in your account during the month, which will detail the activity and the positions in your account. If you have not had any qualifying activity during the month and you have positions in your account, you will receive a quarterly account statement, which details the positions in your account. You may waive the receipt of account via confirmations after each https://stephensaccess.netxinvestor.com/web/stephens/login. You may also receive mutual fund prospectuses, where appropriate. We will provide you periodic reviews of your account. These show how the account investments have performed on an absolute basis. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. General Description of Programs and Services Stephens Capital Management Non-Discretionary Program In the Stephens Capital Management Non-Discretionary Program (“SND”), IARs advise clients regarding their management of client assets on a non-discretionary basis, utilizing both equity and fixed income strategies and, in some cases, alternative investment classes. The goal of SND is to assist clients with the management of their investment assets consistent with the client’s investment objectives and investment strategies, subject to market conditions. SND seeks to fully invest cash balances at all times, and many advised strategies include cash as an asset class in which client assets are invested from time to time. Un-invested cash assets are included in the Stephens Insured Bank Sweep Program (“Bank Sweep Program”), or for Employee Retirement Income Security Act (“ERISA”) or IRA accounts, in a money market mutual fund. From time to time investments include mutual funds. IARs are responsible for providing non-discretionary investment advice, subject to oversight and review by the SCM Supervisory Principals. The SND seeks to assist clients with keeping client assets fully invested at all times, investing assets otherwise un-invested in money market mutual funds. In many accounts, investments include mutual funds or other pooled investment products. SND Fees The maximum annual fee rate is 1%. ADV Part 2A Appendix 1 March 31, 2025 6  The portion of the total fee that is paid to the IAR is 30% to 50%. Stephens Spectrum 401(k) The Stephens Spectrum 401(k) (“SSK”) is a platform designed by Stephens to assist clients’ qualified retirement plans or other deferred compensation programs (“Plan”) to establish an appropriate list of investment options for asset allocation of the investment of plan assets. SSK offers clients the opportunity to invest in a line-up of mutual funds and exchange traded funds (“Funds”), and/or Stephens-designed asset allocation portfolios, that primarily utilize the Funds. Stephens selects a line-up of funds representing each asset class included in the SSK program and establishes and communicates to clients the lineup of Funds and standard SSK asset allocation portfolios for differing risk and time horizon parameters. Ongoing investment selection, monitoring, fund replacement, periodic reallocation, investment performance measurement and quarterly reporting are provided by Stephens, throughout the life of the account. SSK seeks to fully invest cash balances at all times, in the Stephens-designed asset allocation portfolios. Stephens provides investment oversite as a non-discretionary fiduciary to the plan as defined by Section 3(21)(a)(ii) of ERISA. Alternatively, upon the mutual agreement of Stephens and the client, Stephens is able to provide investment oversite as a discretionary fiduciary as defined by Section 3(38) of ERISA. Stephens provides the services described above to clients under a Plan Services Agreement, and Stephens through Pershing also provides, if requested by the Trustee of the Plan, brokerage and/or custodial services needed to effect transactions for SSK accounts and certain compliance functions relating to the services provided by Stephens. If requested by the Trustee, Stephens will conduct group enrollment meetings on dates agreed to by the Trustee and Stephens. Stephens will be available to meet with plan participants in connection with initial enrollment to assist participants in identifying the participant’s investment objectives, risk tolerance, and time horizon. Following initial enrollment, Stephens will be available to meet with individual participants on an as needed basis for investor education. SSK Strategy Changes Stephens may change from time to time the Funds representing any asset class in the standard line-up of SSK Funds, or add or eliminate asset class from the standard SSK platform line-up. Stephens may realign the standard SSK asset allocation portfolios and/or change the Fund selections within the portfolios. The Plan Trustees have discretion to accept any such changes or decline when recommended by Stephens, unless Stephens has agreed to be an ERISA 3(38) fiduciary, and if changes are accepted by the Plan Trustees, the changes will be implemented. SSK Fees and Compensation Fees for the SSK program will be billed to the Plan sponsor or deducted from the client’s assets and collected by the custodian from the client’s account(s) quarterly in arrears at the rates set forth in the Plan Service Agreement. The Percentage fee is applied based on the quarter end asset value and is billed or deducted from client assets. Asset value for the quarter will be computed in accordance with the accounting methodology utilized by the Plan’s Third Party Administrator which may change from time to time. Management Fee The annual fee percentage is based on the projected assets at the end of the year. The fee percent will remain constant through the year unless actual assets significantly increase or decrease and an adjustment is mutually agreed upon by the client and Stephens. The maximum annual fee rate is 0.95%. The portion of the total fee that is paid to the IAR is 30% to 50%. Stephens Capital Management Discretionary Programs In the following types of separately managed accounts, we have the discretionary authority to determine the securities, and the amount of securities, to be bought and sold for our clients without obtaining specific client consent. The discretionary authority regarding investments may, however, be subject to certain restrictions and limitations placed by the client on transactions in certain types of securities or industries or to restrictions or limitations imposed by applicable regulations. Stephens seeks to fully invest cash balances at all times, and many advised strategies include cash as an asset class in which client assets are invested from time to time. Un-invested cash assets are included in the Bank Sweep Program, or for ERISA and IRA accounts in a money market mutual fund. Stephens Capital Management Discretionary Program In the Stephens Capital Management Discretionary Program (“SCMD”), IARs manage client assets on a discretionary ADV Part 2A Appendix 1 March 31, 2025 7  basis, utilizing both equity and fixed income strategies and, in some cases, alternative investment classes. The goal of SCMD is to seek to earn a high total return on investments for the client consistent with the client’s investment objectives and investment strategies, subject to market conditions. IARs are responsible for making day-to-day discretionary investment decisions subject to oversight and review by the SCM Supervisory Principals. In many accounts, investments include mutual funds or other pooled investment products. The client may pursue its own investment objectives, which may include (but are not limited to): Equity: Clients pursuing an Equity investment objective will typically invest in a diversified portfolio of stocks that includes large, medium and small capitalization stocks generally through investments in pooled equity investment products such as mutual funds or exchange traded funds. This strategy seeks to be invested in equity securities at all times. Cash balances can exist pending initial investment or can arise from the sale of securities and/or dividend or distribution payments pending reinvestments. Fixed Income: Clients pursuing a Fixed Income strategy will typically invest in a diversified portfolio of fixed-income securities, which includes municipal bonds, government bonds, corporate bonds or pooled investment products that are invested primarily in fixed-income securities or a combination of different types of fixed income investments. Alternatively, clients pursuing a Fixed Income strategy may invest in a portfolio comprised of investment grade bonds, primarily U.S. Treasury securities. Balanced: Clients pursuing a Balanced strategy will typically invest in a diversified portfolio, with an agreed allocation of portfolio assets in growth equity securities, value equity securities, fixed income securities. The portfolio also can include some exposure to alternative asset classes, such as energy, real-estate, emerging markets or other alternative investment asset classes. In many accounts investments in any of the strategies could include mutual funds, exchange traded funds or other pooled investments. SCMD Management Fee for Equity or Balanced Accounts Clients pay a wrap fee not to exceed two percent (two percent) of assets under management per year for SCM’s services. The portion of the total fee that is paid to the IAR is 20% to 50% . SCMD Management Fee for Fixed Income Accounts Clients pay a wrap fee not to exceed seventy-five basis points (0.75%) of assets under management per year for SCM’s services. The portion of the total fee that is paid to the IAR is 20% to 50%. Stephens Spectrum Program In the Stephens Spectrum Program (“SSP”), SCM manages client assets on a discretionary basis, utilizing primarily mutual funds and exchange traded funds representing a broad spectrum of equity and fixed income markets. In addition, SCM may invest in mutual funds that seek capital appreciation primarily through short positions in domestically traded equity securities and indices, mutual funds that invest in commodities, and mutual funds that employ a merger arbitrage strategy. All accounts are advised and managed by the Spectrum Investment Committee, which has overall responsibility for investment policy, strategy and security selection. The Spectrum Investment Committee is responsible for making day- to-day investment decisions. The goal of SSP is to seek to earn a high total return on investments for the client consistent with the client’s asset allocation boundaries. Prior to January 1, 2022, this program was known as the Asset Allocation and Advisory Services Program (AAA). SSP Management Fee Schedule Clients pay a wrap fee not to exceed ninety-five basis points (0.95%) of assets under management per year for SCM’s services. SSP’s Fee Schedule is as follows: • First $500,000 • Next $2,000,000 • Next $2,500,000 • Next 15,000,000 0.90% 0.70% 0.45% 0.30% ADV Part 2A Appendix 1 March 31, 2025 8  • All over $20,000,000 0.20% The portion of the total fee that is paid to the IAR is a variable rate not to exceed 45%. Stephens Capital Management Fixed Income Strategy In the Stephens Capital Management Fixed Income Strategy (“SCM-FIS”), SCM manages client assets on a discretionary basis using a fixed income strategy. The SCM-FIS is overseen by the Fixed Income Strategy Investment Committee (“Investment Committee”), which has overall responsibility for investment policy, strategy and advises on security selection parameters. SCM IARs make day-to-day investment decisions for accounts advised in the SCM-FIS program within the parameters set forth by the Investment Committee. The Investment Committee seeks to provide consistent performance by actively managing portfolios based on a top down macro investment strategy that adjusts duration and sector allocations on the investment committee’s market views in accordance with evolving economic data, developments and themes. The investment committee employs a strategy of disciplined management of portfolios constructed primarily of investment grade U.S. government, U.S. government agency and corporate bonds with the objective of maximizing risk-controlled returns over full market cycles. The goal of SCM-FIS is to seek to earn a high total return on income securities for the client consistent with the client’s investment objectives subject to market conditions. SCM-FIS seeks to fully invest cash balances into investment grade debt instruments. Clients choosing the Fixed Income Strategy will own a portfolio comprised of U.S. Treasury securities, Government Agency securities, mortgaged backed securities, structured products, municipal bonds and investment grade corporate bonds. Clients may elect to direct deviations from the parameters set forth herein in the management of their particular accounts in appropriate cases. The average maturity of the portfolios will be managed to take advantage of the Investment Committee’s outlook for interest rates. The style of management of the fixed income portfolios managed in the SCM-FIS is duration management. SCM-FIS Management Fee Clients pay a wrap fee not to exceed seventy-five basis points (0.75%) of assets under management per year for SCM’s services. The portion of the total fee that may be paid to the IAR is a variable rate not to exceed 45%. Stephens Capital Management Advisory Services for Employee Benefit Plans The SCM division of Stephens also provides advisory services to employee benefit plan fiduciaries whereby, pursuant to an agreement with plan fiduciaries, SCM assists fiduciaries in choosing primary fund advisers or managers to invest plan funds and in certain cases advises the fiduciaries with respect to allocation of plan assets among funds managed by others. After the initial selection process of the primary advisor, SCM may provide the client with reports analyzing the primary advisor’s performance and comparing such performance with that of other indices with similar investment objectives. In certain cases, the plan compensates SCM for this service based upon a negotiated fee calculated as a percentage of assets under management or a set fee negotiated by the client. In other cases, the primary adviser compensates SCM on a percentage basis. Stephens IA Consulting From time to time Stephens is asked to furnish clients with investment advice through arrangements which involve consultations and recommendations but do not involve trading of securities. In these consulting arrangements, a separate investment Advisory Agreement is entered into specifying the scope of the services which will be provided and the fee to be charged. Consulting services may be provided with a fixed fee, an annual fixed fee paid quarterly or an annual fee paid quarterly based on a percentage of the assets subject to the consulting agreement. Fees are negotiated in advance and are payable as negotiated and agreed to by the client and Stephens. Either party may terminate a consulting agreement upon written notice. In the course of providing these services, Stephens may develop and present periodic reports regarding the client’s investments. The client and Stephens jointly review many of the client’s applicable financial considerations including, but not limited to time horizon, liquidity needs, risk tolerance, net worth, cash flows, education goals, retirement goals, wealth transfer goals and life & long term care insurance needs. Stephens provides the client with personalized financial planning and investment recommendations based upon the information provided by the client and the results of the financial plan. The client is under no obligation to act upon the recommendations of Stephens. If the client does elect to act on any of the recommendations, the client is under no ADV Part 2A Appendix 1 March 31, 2025 9  obligation to effect the transactions through Stephens. Pension Management Trust Program The Pension Management Trust Program (“PMT”) is an asset allocation program, made available to Arkansas Local Pension and Relief Plans (“the Plan(s)”) that were formerly participants in the Arkansas Local Government Pension Management Trust, pursuant to a trust agreement. Under the advice of SCM, as investment advisor, the local board selects certain participating investment management companies (the “Active or Passive Managers”) to direct their investments of funds. Assets may include, but are not limited to, securities, mutual funds, money market funds, collective funds, exchange-traded funds, select individual fixed income securities and other investments. SCM provides advisory services to the Plans, by establishing asset performance comparisons, risk profiles, assisting participants in developing and writing investment policies, preparing asset allocation modeling, and ongoing monitoring of plan portfolios. The selected Active or Passive Managers manage their respective portions of the plan’s assets on a discretionary basis, utilizing Index/Active portfolio management. All accounts are advised and monitored by an IAR of SCM. The participating Active or Passive Managers, which are selected by the pension Plans, make the day-to-day investment decisions and security selections in the program. From time to time, investments in any of the strategies can include mutual funds or separate accounts money management. Stephens or the client can terminate PMT agreements at any time following advance written notice. Compensation Stephens and the local Pension Plan Board will negotiate the specific rate in advance. However, certain services may be provided for a fixed fee on a “per job” basis. The parties will determine such fees through direct discussions. Fees will be payable as negotiated by the parties. SCM shall be paid an annual fee not to exceed one percent (1%) of the value of all investment assets of the plan, payable quarterly in arrears for its services hereunder. The portion of the total fee that may be paid to the IAR is 30% to 50%. Health Management Trust Program The Health Management Trust Program (“HMT”) is an asset allocation program, made available to Arkansas municipalities that become participants in the Arkansas Local Government Health Management Trust (“Participant(s)”), pursuant to a trust agreement. Under the advice of SCM, as investment advisor, the local board selects certain participating investment management companies (the “Active and/or Passive Managers”) to direct their investments of funds. Assets may include, but are not limited to, securities, mutual funds, money market funds, collective funds, exchange-traded funds, select individual fixed income securities and other investments. SCM provides advisory services to the HMT program and to participating accounts, by establishing asset performance comparisons, risk profiles, assisting participants in developing and writing investment policies, preparing asset allocation modeling, and ongoing monitoring of Participant portfolios. The selected Active or Passive Managers manage their respective portions of the Participant’s Plan assets on a discretionary basis. All accounts are advised and monitored by an IAR of SCM. The managers of the funds or other investment portfolios in which the Participant’s Plan assets are invested make the day-to-day investment decisions and security selections in their respective funds or portfolios. The goal of the HMT program is to bring together investment managers creating a customized investment strategy subject to market conditions consistent with each Participant’s Plan’s risk profile and investment objectives, as approved by the Participant. From time to time investments in any of the strategies include mutual funds or separate accounts money management. Compensation Each Participant is expected to negotiate in advance the fee rates to be paid to SCM, as investment advisor, and to the Trustee, the Administrator and the Custodian of Plan assets under the Arkansas Local Government Health Management Trust. However, certain services may be provided for a fixed fee on a “per job” basis. The parties will determine such fees through direct discussions. Fees will be payable as negotiated by the parties. SCM shall be paid an annual fee not to exceed one percent (1%) of the value of all investment assets of the Plan, payable quarterly in arrears for its investment advisory services hereunder. The portion of the total fee that may be paid to the IAR is 30% to 50%. Comparing Costs ADV Part 2A Appendix 1 March 31, 2025 10  Depending on the level of trading and types of securities purchased or sold in your account, you may be able to obtain transaction execution at a higher or lower cost by purchasing securities separately at Stephens than by paying an asset- based fee in these Programs. Additional Fees In these Programs, you will pay Stephens an asset-based fee for investment advisory and other services provided by Stephens or Pershing. These services include custody of securities and trade executions through Pershing on behalf of Stephens. In some circumstances, the program fees do not cover: • • • • • • the costs of investment management fees and other expenses charge by Funds and UITs; “mark-ups”, “mark-downs”, and dealer spreads that Stephens receives when acting as principal in certain transactions where permitted by law; brokerage commissions or other charges resulting in transactions not effected through Stephens with Pershing; account transfer fees; processing fees; or certain other costs or changes may be imposed by third parties. As your Introducing Broker Dealer, Stephens can receive or pay compensation for directing order flow in equity securities. Pershing receives compensation for the direction of order flow in certain equity securities and listed options; the source and nature of the compensation, if any, received in connection with trades will be furnished upon your written request to your IAR. Stephens Insured Bank Sweep Program The Stephens Insured Bank Sweep Program (“Bank Sweep Program”) is available to Stephens’ clients through Pershing, and Pershing has appointed IntraFi Network LLC (“IntraFi”) to provide certain services in connection with the Bank Sweep Program. In the Bank Sweep Program, each bank participating in the program pays a return based on the amount of funds in your Deposit Account at the bank. The interest rate applicable to your Deposit Accounts is determined by the amount of interest participating banks are willing to pay on the aggregate balance of the deposits minus: (i) the fees paid to IntraFi, as administrator, (ii) the fees paid to Pershing for its services, and (iii) the fees paid to Stephens. Stephens retains and exercises the right to negotiate its own fee and may reduce or increase its fee. Because an increase in fees to Stephens reduces the effective amount of the interest rate that is ultimately paid to customers, Stephens has a conflict of interest with regard to the Bank Sweep Program. Stephens’ compensation, exclusive of the fees paid to Pershing and IntraFi, for the Bank Sweep Program as applied to all clients will not exceed 6% per annum on the aggregate balances in the Deposit Accounts at the program banks. The total amount of the fee Stephens charges affects the amount of interest payable to clients on their Deposit Accounts since the higher Stephens’ fee is, the lower the amount of interest that is paid to Stephens’ clients. Stephens charges investment advisory fees as a percentage of client assets under management which includes cash assets in the Bank Sweep Program. This means that clients will pay Stephens’ investment advisory fee in addition to the fees charged in the Bank Sweep Program which are described above. More information on the current rates of return and fees is available at www.stephens.com/investment-disclosures/, which is incorporated herein. The interest rates on the Deposit Accounts will vary based upon the value of the assets you maintain in your Stephens’ household accounts, including amounts on deposit in your Deposit Accounts (“Interest Rate Tiers”). The rates and the Interest Rate Tiers may change from time to time. Further information on the Bank Sweep Program is available at https://www.stephens.com/investment-disclosures/stephens-insured-bank-sweep-program-rates/. These disclosures are incorporated herein. The interest rates paid on the Deposit Accounts at a Bank may be higher or lower than the interest rates available to depositors making deposits directly with the Bank or other depository institutions in comparable accounts and for investments in the money market mutual funds and other cash equivalent investments available through Stephens. You should compare the terms, interest rates, required minimum amounts, and other features of the Bank Sweep Program with other accounts and alternative investments. In deciding whether to participate in the Bank Sweep Program, clients should consider the return they are expected to receive versus the safety of the program. Banks participating in the Bank Sweep Program are not selected by Stephens, and each bank participating in the Bank Sweep Program is covered by FDIC deposit insurance up to the applicable FDIC ADV Part 2A Appendix 1 March 31, 2025 11  limit. Banks in the program are expected to have acceptable credit but may not have “top tier” credit, and clients should evaluate credit quality and FDIC insurance coverage together with the return they are expected to receive. Funds in Advisory Programs Investing in Funds is more expensive than other investment options offered in your advisory account. In addition to our investment advisory fee, you pay the fees and expenses charged by the 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 of the Fund’s share price. These fees and expenses are an additional cost to you and are not included in the fee amount in your account statement. Each Fund expense ratio (the total amount of fees and expenses charged by the Fund) is disclosed in its prospectus. You do not pay a sales charge for purchases of mutual funds in your advisory account. However, some mutual funds charge, and do not waive, a redemption fee on certain transaction activity in accordance with its prospectus. In many instances, client account assets are invested in money market funds, mutual funds, other investment companies, privately offered investment funds and other collective vehicles (collectively, “Funds”), and these investments have their own fees and expenses which are borne directly or indirectly by their shareholders. Where Stephens or its affiliates act as investment advisor, sponsor, administrator, distributor, selling agent, or in other capacities to such Funds, these Funds are deemed to be “Affiliated Funds.” Stephens or a Stephens affiliate receives the fees paid pro rata by all shareholders or partners of Affiliated Funds as described in the Fund’s prospectus. Client account assets can also be invested in Funds, which are unaffiliated with Stephens or a Stephens’ affiliate (“Unaffiliated Funds”). For both Affiliated Funds and Unaffiliated Funds in which Stephens’ client assets are invested, Stephens, via Pershing, receives shareholder servicing fees and 12b-1 fees from Funds on an ongoing basis as compensation for the administrative, distribution and shareholder services provided by Stephens. These services include such things as record maintenance, shareholder communications, transactional services, client tax information, reports filings and similar such services. These fees are paid under a plan adopted by the Funds pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended. If Stephens receives 12b-1 fees from a Fund with respect to a client’s mutual fund investment in the client’s account and the client is paying Stephens an advisory fee on such investment, the 12b-1 fees are rebated to the client’s advisory account. However, in client brokerage accounts which have mutual fund holdings, Stephens does retain the 12b-1 fees and shareholder servicing fees paid by the funds on these mutual fund holdings. Mutual funds are available to investors in a variety of different share classes all of which carry different expense ratios. Fund share classes that pay higher compensation carry higher expense ratios than share classes of the same mutual fund with lower expense ratios. Investing in a mutual fund share class with a higher expense ratio will negatively impact an investor’s return. Consistent with our fiduciary duty to clients, Stephens will take reasonable steps to ensure advisory clients are invested in share classes of mutual funds with the most appropriate expense ratio for their advisory account. Not all share classes are available to advisory clients of Stephens, and it is possible that cheaper share classes of a fund may be available directly with the fund not available on the Pershing platform or away from Stephens. Additionally, because of the large number of mutual funds which are offered in an ever changing variety of different share classes, it is possible that investors may not receive cheaper share classes which come available after their initial investment in a fund. Unit Investment Trust (“UIT”) Sales Charge There are characteristically two components of the UIT sales charge: the transactional sales fee and the creation and development ("C&D") fee. The transactional sales fee does not apply to advisory accounts. The C&D fee is paid to the sponsor of the trust for creating and developing the trust, which includes determining the trust objectives, policies, composition and size, selecting service providers and information services as well as providing other similar administrative and ministerial functions. Your trust pays the creation and development fee as a fixed dollar amount at the close of the initial offering period. The sponsor does not use the fee to pay distribution expenses or as compensation for sales efforts. Affiliated and Certain Funds Clients that invest in mutual funds advised by Hotchkis & Wiley Capital Management LLC (“H&W”) or advised/sub- advised by Stephens Investment Management Group LLC (“SIMG”) would bear a proportionate share of the fees and expenses of those funds including the management fees, sub-advisory fees or other fees paid to H&W or SIMG. These fees and expenses include commissions or fees, if any, paid to Stephens in connection with portfolio transactions. Please refer to each mutual fund’s prospectus for a full discussion of the fees and expenses of each mutual fund. An affiliate of Stephens has an ownership interest in H&W, and SIMG is under common control with Stephens. ADV Part 2A Appendix 1 March 31, 2025 12  Custodial Services Effective November 15, 2019, Stephens entered into a fully disclosed clearing arrangement with Pershing wherein Pershing provides certain recordkeeping and operational services to Stephens and to Stephens’ clients. The services provided by Pershing include execution and settlement of securities transactions, custody of Stephens’ client accounts and extensions of credit for any margin transactions. Pershing, normally provides custodial account services to Stephens’ clients. Custodial services provided by Pershing include custody of securities in your account, periodic statements, certain tax reporting and other similar services. Pershing is a subsidiary of the Bank of New York Mellon Corporation and is located at One Pershing Plaza, 4th Floor – Jersey City, NJ 07399. Pershing will send your account statements, which you should carefully review. In addition to the account statements Pershing sends you, we may send you a quarterly performance report which among other things, lists your account holdings and performance. You should compare our report to the account statements you receive from Pershing. In the event of any discrepancy between our report and any statement you receive from Pershing regarding the same investment, you should rely on the statement from Pershing. Your account will be subject to the terms and conditions described in the Advisory Contract, Agreement and any separate agreement or agreements executed in connection with the account. Stephens includes custodial fees for custody services and securities services provided by Pershing within the wrap fee charge. If a client’s account is under a wrap fee Program, commission charges are included as part of the Stephens advisory fee unless the client has selected a third party adviser who “trades away” from Pershing. Clients may engage an independent custodian. The fees of any custodian other than Pershing are not covered by the wrap fee and are the separate responsibility of the client. Clients may direct trading through another broker or other execution venue, and, in such a situation, the client will be responsible for all costs and commissions incurred in connection with such trading. Pershing Relationship Pershing is the clearing firm for our securities business. Due to this business relationship, Pershing shares with us a portion of the transaction costs and fees you pay to Pershing for certain transactions and services. This compensation we receive is an additional source of revenue to Stephens, and it defrays our costs associated with maintaining and servicing client accounts. Your advisory fee is not reduced or offset as a result of any revenue that Pershing shares with Stephens. The following is a brief description of some of the revenue and other items. • Pershing pays us on a quarterly basis an Active Account Credit in support of our ongoing investment in various businesses, marketing and technology initiatives relating to the services we offer. This Active Account Credit is based on the total number of Stephens client accounts held on the Pershing platform. • Pershing also pays us a Basis Point Credit each quarter which is computed based on the total value of Stephens client accounts held on the Pershing platform. • Pershing also provides consulting and other assistance to us from time to time. • Stephens receives revenues from Pershing on any investor free credit balances. These revenues are not received by Stephens for free credit balances in ERISA or IRA accounts. • Stephens determines the margin debit interest rate and receives any amounts paid by customers in excess of the Fed Funds Target Rate plus 85 basis points. • Stephens determines the interest rate charged to clients who obtain non-purpose loans within parameters set by Pershing. Stephens receives 100 bps of the interest paid on the loan from Pershing except in situations where Stephens has agreed to receive a lesser amount. • Pershing pays us a placement fee for each CD purchased through Pershing by a Stephens’ client. • Pershing pays us a portion of the revenues it receives for banking services provided to clients. For the period January 1, 2024 through December 31, 2024, Pershing paid Stephens the following revenues: Interest based on investor free credit balances of $1,900,734 • A short interest rebate of $1,714,766 • • Margin interest credit of $836,256 • Active account and basis point credits of $1,563,496 • Non Purpose Loan interest of $617,507 • Silver Account (i.e. checking account) fee of $35,750 • Fee Income-Pershing-Legal/Transfer $7,600 • Pershing-Money Market Invesco ATRR $243,432 ADV Part 2A Appendix 1 March 31, 2025 13  Where Stephens receives compensation from Pershing, this presents a conflict of interest because Stephens and your IAR have a greater incentive to make available, recommend, or make investment decisions regarding investments and services that provide additional compensation over those investments and services that do not. The Clearing Agreement between Stephens and Pershing is for an initial term of 10 years, and it provides for a substantial termination penalty in the event Stephens terminates the Clearing Agreement prior to the end of the initial term. At the outset of the Clearing Agreement, the termination penalty was $15 million, and it declines $2 million each year to $5 million in years 6 through the end of the Clearing Agreement. The termination penalty serves as a disincentive for Stephens to terminate the Clearing Agreement in the event Stephens or its clients have a negative experience with Pershing or if Stephens believes another firm offers superior service. This creates a conflict of interest in that it could influence Stephens’ decision to remain with Pershing even though it may be in the best interest of Stephens or its clients to terminate the Clearing Agreement. You should only use the cost basis information provided on your custodial account statements for tax reporting purposes. Pershing’s mailing address is: Pershing LLC; One Pershing Plaza; Jersey City, New Jersey 07399. For IRA and other retirement accounts, Pershing may charge termination fees pursuant to an adoption agreement you enter into with Pershing, which authorizes Pershing to act as the IRA custodian for Internal Revenue Service purposes. Pershing may resign at any time as the IRA custodian and then you have the right to appoint a successor IRA custodian (Successor). Where an unaffiliated third party acts as custodian of account assets, Stephens does not have discretion to select where cash reserves will be held. The client and/or custodian will make the selection. ERISA and IRA Fees Fees charged by Stephens to accounts of ERISA or Internal Revenue Code-covered plans will comply with the limitations made applicable under ERISA or the Code. Where Stephens or an IAR provides non-discretionary investment advice such as recommending the rollover of a 401k to an IRA account at Stephens, recommending opening an IRA account with Stephens, or recommending the transfer of an IRA from another firm to Stephens, this presents a conflict of interest since compensation will be paid to Stephens and the IAR in connection with these services. In addition, Stephens charges different levels of fees on different investment services. Stephens has adopted policies and procedures to mitigate these conflicts, and to address provisions of and prohibitions under ERISA and the Code with respect to potential conflicts of interest and self-dealing. ERISA Section 408(b)(2) Disclosures You may be, or may be acting on behalf of, a pension plan governed by the Employee Retirement Income Security Act of 1974, as amended (ERISA). ERISA section 408(b)(2) requires most parties that provide services to employee benefit plans to disclose certain information to a responsible plan fiduciary. Generally, the service provider must disclose the services that it provides to the plan and the compensation that it expects to receive in connection with the services. Stephens’ disclosures are available at the following web address: www.stephens.com/ERISA408b2 If you are the responsible plan fiduciary, please view the disclosures on this website. If you are not the responsible fiduciary, please forward this information to the responsible fiduciary of the plan. Please review this website periodically for any required updates. Principal Transactions Pursuant to SEC Rule 206(3), Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing the capacity in which it is acting. As a practical matter, the above requirements impose delays on the time at which principal transactions can be effected for advisory accounts, and thereby can impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. Investment advisory clients are advised that they have the option to seek execution of transactions recommended by the ADV Part 2A Appendix 1 March 31, 2025 14  IAR through broker-dealers other than Stephens. However, on transactions executed through Stephens with Pershing, Stephens or Pershing will not charge a commission to the client, except when an underwriting issue in which Stephens participates is purchased for an account; in this case, the sales concession and underwriting fees are built into the offering price. Stephens will strive to obtain “best execution” of transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances. Transactions in securities in which Stephens acts as a principal will only be effected for clients subject to the client’s written consent to such transaction indicating the quantity and dollar amount of the securities being purchased or sold. If Stephens is acting as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a client. IPO Retail Client Allocations Although underwriting initial public offerings (“IPOs”) on behalf of corporate and other types of issuer clients is a regular part of Stephens’ investment banking business, the frequency, share price, number of shares available, and other characteristics of such offerings vary widely over time. For example, in some years Stephens may participate as an underwriter in no, or only a few, IPOs. Factors that limit IPO product availability to clients through Stephens include: • Market conditions that make raising capital through IPOs less favorable or unfavorable for issuers, such as periods of high market volatility or depressed share prices. • Alternative investment options for institutional and retail investors that impact overall demand for IPO investments. • Lack of or diminished investor interest in market sectors in which Stephens’ issuer clients operate. • The availability of capital through other sources such as the private equity marketplace or attractive debt financing alternatives. • Diminished financial strength and business prospects of particular issuer clients that make them poor candidates for IPOs. • Lack of specific business needs of particular issuer clients for capital infusions. In addition, in many instances Stephens will only be a small participant in an IPO underwriting syndicate that is led by another firm or firms and, consequently, will have little or no control or influence over whether, or to what extent, shares in the IPO are allocated to retail accounts and, instead, are directed to institutional clients. The combination of these factors makes it impractical, if not impossible, for Stephens to determine how much and what types of IPO product will be available for allocation to its retail client accounts over any extended time period. That, in turn, effectively precludes Stephens from utilizing any type of rotational allocation system designed to ensure that all of its retail client accounts are treated equitably. Instead of attempting to allocate shares equitably across all retail client accounts, Stephens bases its share allocation decisions on an account-by-account methodology taking into consideration multiple factors, including the following: • The number of shares available in the IPO for allocation to Stephens’ retail clients. • The customary desire of Stephens’ issuer clients to avoid small retail allocations to numerous accounts, which would increase the cost and administrative burden of communicating and dealing with unnecessarily large numbers of investors. • Share allocation requests received by the Stephens syndicate department from the brokers (“IARs”) who manage the firm’s retail client accounts. • The level of sophistication of the IAR submitting those allocation requests in evaluating and dealing with IPO investments. • The stated interest of a particular retail client in participating in IPOs, in general, or in a particular IPO, including the number of shares requested. • The suitability of the investment for the client, particularly if it is speculative in nature, as is sometimes the case in IPOs. • Whether the requested IPO allocation would result in an overconcentration of the security in the client’s account, resulting in lack of appropriate diversification. • Whether the IPO investment would be consistent with the investment strategy and objectives agreed to by the client and the IAR. • Any applicable tax considerations. ADV Part 2A Appendix 1 March 31, 2025 15  • Whether the client has adequate liquidity in the account, or otherwise, to fund the IPO investment. • Whether the IAR is able to contact the client on a timely basis and obtain any documentation necessary to participate in the offering. • Whether based on the client’s prior investment practices or discussions with the IAR, it appears likely that the client intends to quickly resell the shares in order to obtain short term trading profits as opposed to holding them in order to gain long term appreciation, sometimes referred to as “flipping.” Given the complexity and sometimes subjective nature of this analysis, and the fact that the applicability these considerations may vary with respect to a particular retail client at any given time, Stephens does not attempt to ensure that the allocation of IPO shares across all of its retail client accounts is equitable and does not analyze the fairness of its allocation decisions over time. In practice, some retail client accounts will have far greater access to IPO allocations than others. In fact, based on past experience, only a very small percentage of Stephens’ retail clients will participate in IPOs. Nevertheless, clients who are interested in participating in IPOs or a particular IPO are encouraged to advise their IAR of such fact. IPO Related Conflicts of Interest Flipping. Stephens has a long-standing policy of discouraging its IARs from allocating IPO securities to retail client accounts that appear likely to quickly resell the securities in order to obtain short term trading profits as opposed to holding them in order to gain long term appreciation. Excessive short term trading in the secondary market following an IPO has the potential of causing market disruption and depressing the price of the issuer’s securities, both of which would operate to the disadvantage of Stephens’ issuer clients. Accordingly, Stephens reserves the right to withhold IPO allocations to retail client accounts that have a history of flipping their IPO securities positions or advise their IAR of their intent to flip the IPO securities they wish to purchase in a pending IPO. This policy creates a conflict of interest because, while it favors Stephens’ IPO issuer clients and Stephens’ long term interests as an underwriter, it may not be in the best interest of a retail client seeking to realize short term trading profits on the client’s IPO positions. In addition, Stephens may penalize clients who flip their IPO securities by reducing or eliminating IPO allocations to them in the future. Favoring Larger Allocations. Stephens’ issuer clients generally prefer that the underwriting syndicate avoid small retail allocations to numerous accounts, which would increase the cost and administrative burden of communicating and dealing with unnecessarily large numbers of investors. Major items of expense in that regard include the printing and mailing of large numbers of investor communications such as proxy statements and annual reports. Further, Stephens, itself, incurs higher transaction and administrative costs if smaller IPO allocations are spread over a larger number of accounts. This overall situation creates a conflict of interest with respect to Stephens’ handling of smaller accounts because larger allocations mean that they will have less opportunity to participate in IPOs and gain the IPO experience that would potentially qualify them for participation in more IPOs. This methodology also has the potential of increasing risk for IPO investors to the extent that larger allocations would be expected to result in more concentration with respect to these types of typically more speculative securities. Advisory vs. Brokerage Accounts. If a retail client has both an advisory and a brokerage account, it may be in the best interest of the client to purchase IPO securities in the brokerage account. The client would pay the same offering price for the securities irrespective of which type of account is selected for the purchase. However, in a brokerage account no additional charges (in the form of commissions) would be incurred until the time the securities are sold, while in an advisory account the client would incur assets under management fees that could exceed the amount of such commissions depending on the length of the holding period. The risk of this disadvantage occurring is increased by Stephens’ policy against flipping, which is designed to encourage longer holding periods. Offerings with Less Demand. Based on Stephens’ previously described allocation process, there is a potential that a retail account that does not frequently participate in IPOs may have a greater opportunity to participate in IPOs that prove to be in less demand, particularly if Stephens receives a relatively large allocation for placement with its retail clients. Although Stephens, and its IARs, have limited ability to predict client demand for an IPO in advance of the pricing and effectiveness of the offering, certain of the criteria utilized in allocating shares, such as previous IPO experience and favoring larger allocations, may result in more favorable allocations to larger, more experienced retail accounts in connection with high demand offerings. On the other hand, these factors would be expected to have less of an impact with respect to offerings where there is less demand from retail clients relative to the size of the retail allocation Stephens receives. It is likely, although certainly not guaranteed, that IPOs for which there is high demand relative to supply will perform better in the post-offering marketplace for at least some period of time. Clients That Do Not Have Access. Stephens relies primarily on its IARs to determine whether, and to what extent, their retail advisory clients are interested in participating in IPOs. Many accounts are simply too small to participate in IPOs ADV Part 2A Appendix 1 March 31, 2025 16  when concentration and suitability factors are taken into consideration. And, in practice, only a small percentage of Stephens IARs regularly submit IPO allocation requests on behalf of their clients. In many instances, retail clients are participating in one or more of the Stephens Capital Management advisory platforms providing for fee based, discretionary management by the IAR, a firm investment committee or a third party money manager. The vast majority of IARs rely on these platforms to achieve appropriate asset allocation for their clients and typically do not offer their clients the opportunity to participate in IPOs. Finally, Stephens IARs, in their discretion, may elect to offer IPO allocations to some clients but not others, and such decisions are unlikely to be reviewed by Stephens Capital Management supervisors or Compliance Department personnel. Given these circumstances, retail clients interested in participating in IPOs should advise their IAR of such fact. In addition to existing programs, Stephens added new platforms for IRA and ERISA accounts. These platforms provide for low cost, level fee charges to clients, and Stephens is not allowed to accept any other compensation with respect to the handling of the account, including the compensation it would receive in connection with the sale of IPO securities. Accordingly, Stephens does not allow these types of accounts to participate in IPOs. Compensation to the Investment Adviser Representative If you invest in one of the Programs described in this brochure, a portion of the fees payable to Stephens in connection with your account is allocated on an ongoing basis to your IAR. The amount allocated to your IAR in connection with accounts opened in one of these Programs may be more or less than other investment advisory programs, or brokerage and other services. The payout to the IAR on these programs typically ranges from 20 – 50%. Item 5: Account Requirements and Types of Clients Account Minimums Generally, a minimum of assets is not required for the establishment of a SCM investment advisory account. Types of Clients Stephens’ clients include individuals, trusts, banking and thrift institutions, pension and profit sharing plans, plan participants, charitable organizations, corporations, other businesses, state and municipal entities, investment clubs and other entities. Item 6: Portfolio Manager Selection and Evaluation Selection and Review of Portfolio Managers SND – Non Discretionary As SND is a non-discretionary advisory program where the client retains authority to make investment decisions, Stephens does not review, select or recommend portfolio managers. However, the IAR must be appropriately licensed and have an acceptable compliance record. SCM Discretionary, Stephens Spectrum, Stephens Spectrum 401k and SCM-Fixed Income Programs As a general rule, Stephens requires each IAR to have a college degree and extensive experience with securities brokers, investment advisors, asset managers, investment bankers, financial institutions, insurance companies, or equivalent institutions. Such standards may be waived in exceptional cases. The IAR must be appropriately licensed, have an acceptable compliance record, be approved by SCM senior management and the Chief Operating Officer. All IARs are employees of Stephens. Review of Portfolio and Performance We utilize a portfolio system licensed from a third party to calculate the performance of client accounts and to prepare portfolio performance reports for clients. To determine the value of securities in your account, we generally rely on third party quotation services. If a price is unavailable or believed to be unreliable, Pershing may determine the price in good faith and may use other sources such as the last recorded transaction. SCM Non- Discretionary, SCM - Discretionary Performance is evaluated using internal metrics as well as industry standards. Stephens may periodically review performance information to determine compliance with company standards. Performance information to be used for ADV Part 2A Appendix 1 March 31, 2025 17  evaluation purposes will not always be calculated on a uniform and consistent basis. The Supervisory Principal periodically reviews performance information to determine compliance, as further discussed in Item 9. Your IAR may use a wide variety of investments in your advisory accounts, including equity and debt securities of various kinds, exchange traded funds, mutual funds and other securities or other pooled investment products. Subject to approval by Stephens you may also consider using margin, short-term trading and option strategies, including but not limited to covered calls and protective puts. Stephens Spectrum Investment Committee The Spectrum Investment Committee management of accounts in the Stephens Spectrum Program is overseen and reviewed by the SSP Committee, which is composed of: Brian Bush Doug Seelicke Warren Simpson Typically, client assets are managed utilizing mutual funds, exchange traded funds or other similar investments representing a broad range of equity and fixed income markets. Such investment advice and management services will be limited to only those assets, securities and other property, which the client designates as being covered by SCM's authority. In determining the appropriate model for each account within its pre-approved range of models, the committee members may utilize its analysis of the equity market earnings yield compared to interest rates. In addition they consider a wide range of other financial and economic criteria and indicators. Members of the Spectrum Investment Committee regularly monitor the performance of the Spectrum investment portfolios. SCM Fixed Income Strategy Investment Committee Investment Committee Management of accounts in SCM-FIS is overseen and reviewed by the Fixed Income Strategy Investment Committee, which is composed of: Larry Bowden, EVP, Mgr. Fixed Income Sales and Trading Troy Clark, SVP Fixed Income Risk Manager David Moix, Managing Director Abigail Buchanan, SVP Trading Analyst Larry Middleton, EVP Bo Brister, SVP Brian Baumeister, SVP The Fixed Income Strategy Investment Committee has overall responsibility for oversight of the strategy, sets policy and advises on security selection parameters. The Stephens Fixed Income Investment Strategy Investment Committee seeks to provide consistent performance by actively managing portfolios based on a top down macro investment strategy that adjusts duration and sector allocations on the Investment Committee’s market views in accordance with evolving economic data, developments and themes. The Investment Committee is comprised of six tenured industry professionals that have in excess of 160 years of combined investment-related experience. SCM IARs make day-to-day investment decisions for accounts advised in SCM-FIS within the parameters set forth by the Investment Committee. Duration decisions are made by SCM IARs within the parameters established by the Investment Committee. Clients may set their own boundaries for duration variance from any given benchmark. Our investment management service seeks to tailor an investment program for the unique financial circumstances and objectives of a particular client. When we are engaged as an investment manager, the client typically pursues one or more of our investment strategies. Clients can impose investment restrictions on the IAR of their accounts, such as restrictions on investing in particular securities or types of securities or restrictions on investing in particular industries. Conflicts of Interest Conflicts of Interest Ownership Pursuant to SEC Rule 206(3), Stephens, acting as a principal for its own account, will not knowingly sell any security to ADV Part 2A Appendix 1 March 31, 2025 18  or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing the capacity in which it is acting. As a practical matter, the above requirements may impose delays on the time at which principal transactions may be effected for advisory accounts, and thereby may impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. Transactions in which Stephens acts as a principal will only be effected for clients subject to the client’s written consent to such transaction indicating the quantity and price of the securities being purchased or sold. If Stephens is acting as a market-maker or otherwise as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a client. American Beacon Stephens Funds® and Hotchkis & Wiley Funds (“Affiliated Funds”) are funds managed by affiliates of Stephens and/or advisors in which affiliates of Stephens have a substantial ownership interest. ERISA accounts and IRA accounts are generally prohibited from investing in these Funds. Other advisory accounts may invest in the Affiliated Funds in an appropriate amount if: (1) the manager and the client determine that the investment is suitable for the account, and (2) the client signs an Affiliate Funds Consent Letter (“Consent Letter”) prior to directing the purchase of the affiliated fund shares. Hotchkis and Wiley Limited (“HW-UK”), a wholly-owned subsidiary of H&W, is a private limited company incorporated in England and Wales. HW-UK is an appointed representative and tied agent of Arlington Group Asset Management Limited (AGAM) since March 1, 2016. AGAM is authorized by the Financial Conduct Authority to carry out regulated activities. The Chief Executive of HW-UK is also an appointed representative of AGAM and may carry on certain regulated activities in Europe. Portfolio Management by Advisors Owned or Partially Owned by Stephens Affiliated Mutual Funds Stephens may from time to time engage in transactions on behalf of clients with Hotchkis & Wiley Capital Management LLC (“H&W”) or with mutual funds advised by H&W. H&W is an investment adviser registered with the SEC in which entities under common control with Stephens hold an ownership interest. H&W provides investment advisory services to corporate, pension, public, endowment, foundation, mutual fund and other clients, and H&W also advises its own family of mutual funds. Stephens may also from time to time engage in transactions on behalf of clients with Stephens Investment Management Group LLC (“SIMG”) or with mutual funds advised by SIMG. SIMG is an investment adviser registered with the SEC in which affiliates of Stephens hold the entire ownership of voting securities. SIMG provides investment advisory services for separate account clients and for mutual funds known as the American Beacon Stephens Funds® or other funds which may be added from time to time. Additionally, SIMG serves as one of the investment advisors to the following multi-manager mutual funds using its SMID Select Growth Strategy or Small Cap Growth Strategy: • Vanguard Explorer™ Fund; and • Bridge Builder Small/Mid Cap Growth Fund; and • First Trust Multi-Manager Small Cap Opportunities ETF (MMSC) H&W advised mutual funds and SIMG advised mutual funds are offered through Stephens’ broker dealer services and/or investment advisory services as part of an investment program. Clients that invest in H&W advised mutual funds or in SIMG advised mutual funds would bear a proportionate share of the fees and expenses of those funds including the management fees or other fees paid to H&W or SIMG. These fees and expenses include commissions or fees, if any, paid to Stephens in connection with portfolio transactions. Please refer to each mutual fund’s prospectus for a full discussion of the fees and expenses of each mutual fund. Stephens Sponsored Wrap Fee Program Stephens sponsors the Stephens Small-Mid Cap Core (“SMID Core”) Growth Program which is a wrap fee program sub-advised by SIMG that follows its SMID Core Growth Model. FCs are not financially incentivized to place clients in the SMID Core Growth Program versus any other wrap program or platform available at Stephens. However, a portion of the SMID Core account fees, generally representing twenty to fifty percent (20%-50%) of SMID Core fees, will be paid to SIMG for its portfolio management services, pursuant to a sub-advisory agreement between Stephens and SIMG. SIMG and Stephens share common ownership, which benefits from the compensation generated to SIMG as ADV Part 2A Appendix 1 March 31, 2025 19  the result of a client investing in the SMID Core Growth Program. Depending on the level of trading, the value of the account, and types of securities purchased or sold, clients may be able to obtain transaction execution at a higher or lower cost if purchased separately at Stephens or SIMG than through this wrap fee program. Affiliated Investment Management Activities Certain investment strategies offered by SIMG have been selected for inclusion in the Private Client Group’s (“PCG”) Managed Assets Program (“MAP”). Sub-Advisors and strategies may only participate in MAP if they have been approved by the MAP Investment Committee. The MAP Investment Committee employs a process for evaluating investment managers that includes both qualitative and quantitative factors. SIMG strategies participating in MAP are subject to the same due diligence and evaluation processes as sub-advisors or strategies that have no affiliation with Stephens. FCs are not financially incentivized to favor selecting SIMG strategies over non-affiliated sub-advisors or strategies. However, selection of an SIMG strategy in MAP generates compensation to SIMG, which shares common ownership with Stephens. Other Affiliations Certain entities affiliated with Stephens or under common control with Stephens hold an ownership interest in Alex Brown Realty, LLC, a registered investment adviser. From time to time, Stephens offers to its clients securities sponsored by Alex Brown Realty, LLC. Stephens sometimes refers clients to Stephens Insurance, LLC, an affiliated insurance agency under common control with Stephens, for advice pertaining to products that are provided through Stephens Insurance, LLC, and IARs may be eligible, subject to regulatory and legal requirements, to receive referral fees for insurance business referred. For further information that pertains to related persons of Stephens, please refer to “Other Potential Conflicts of Interest”. Other Potential Conflicts of Interest Stephens is a diversified financial services company that directly or through affiliates provides a wide variety of investment banking, securities, insurance and other investment-related services to a broad array of clients. These relationships could give rise to potential conflicts of interest. Any of the following types of transactions could present a potential for a conflict of interest.  Client account assets can be invested in interests of money market funds, mutual funds, other investment companies, privately offered investment funds and other collective vehicles (collectively, “Funds”) for which Stephens or its affiliates acts as investment advisor, sponsor, administrator, distributor, selling agent, or in other capacities (“Affiliated Funds”). In addition, client account assets can be invested in interests of Funds for which Stephens or its affiliates do not act as investment advisor, sponsor, and administrator or in other capacities. Stephens or its affiliates receive fees for services provided to such Funds, which often include (but are not limited to) fees payable under a plan adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (“12b-1 fees”) and fees paid to compensate Stephens for providing administrative services, distribution services, shareholder services, investment advisory services or other services to or for the benefit of such Funds. Stephens as a dually-registered broker-dealer is paid the retail 12b-1 fees for brokerage mutual fund investments. Where 12b-1 fees are received in advisory accounts, these fees are rebated to the client’s advisory account.  From time to time, client account assets are invested in transactions that involve or constitute a purchase, sale or other dealings with securities or other instruments for which (i) Stephens, (ii) an affiliate or employee of Stephens, (iii) an entity in which Stephens or an affiliate has a direct or indirect interest, or (iv) another member of a syndicate or other intermediary (where an entity referred to in (i), (ii), or (iii), above is or was a member of the syndicate), has acted, now acts, or in the future may act as an underwriter, syndicate member, market maker, dealer, broker, principal, agent, research analyst or in any other similar capacity, whether the purchase, sale or dealing occurs during the life of the syndicate or after the close of the syndicate. Stephens has an incentive to favor the securities of issuers for which it provides such services over the securities of issuers for which Stephens does not provide such services. Your IAR also receives more money if you buy these investments.  From time to time, Stephens and its FCs and/or IARs may recommend that clients invest in investment products that are affiliated with Stephens. Such arrangements are described in greater detail above. Such a recommendation of affiliated investment products creates a potential conflict of interest because Stephens, its affiliates, and their beneficial owners may receive higher aggregate compensation than if clients invest in unaffiliated investment products. Stephens addresses this potential conflict through disclosure, including in this Brochure. Additionally, when acting as fiduciaries, Stephens FCs and IARs are required to recommend affiliated investment products only when they determine it is in the client’s best interest to do so. FCs or IARs are not financially incentivized to recommend Stephens-affiliated products over any other investment product ADV Part 2A Appendix 1 March 31, 2025 20  available at Stephens. In no case are you under any obligation to purchase any products or services sold by us or our affiliates.  Although underwriting initial public offerings on behalf of corporate and other types of issuer clients is a regular part of Stephens’ investment banking business, the frequency, share price, number of shares available, and other characteristics of such offerings vary widely over time. For example, in some years Stephens may not participate as an underwriter, or in only a few, IPOs. For factors that limit IPO product availability to clients through Stephens see Item 5(C) Fees and Compensation/IPO Retail Client Allocations/IPO Related Conflicts of Interest for more detail.  Stephens or any other broker-dealer that is or may become affiliated with Stephens (the “affiliated brokers”), is expected to act as broker or dealer to execute transactions on behalf of client’s account. Clients will not be charged a separate fee for brokerage services provided to the account by affiliated brokers.  Stephens or its affiliates sometimes effect transactions for the client’s account with other accounts for which Stephens or an affiliate provides investment advisory services (“Cross Trades”). Such Cross Trades are intended to enable Stephens to purchase or sell a block of securities at a set price and possibly avoid an unfavorable price movement that may be created through entrance into the market with such purchase or sell order. Stephens receives compensation from other accounts involved in a Cross Trade.  Subject to applicable regulations, Stephens or its affiliates sometimes execute “Agency Cross Transactions” for the client’s account. Agency Cross Transactions are transactions where Stephens, or any affiliate of Stephens, acts as broker for both the client’s account and the other party to the transaction. In such transactions, Stephens, or any of Stephens’ affiliates acting as broker, receives commissions from the other party to such transaction, to the extent permitted by law, in addition to its customary investment management or advisory fee for the client’s account.  Clients of other divisions of Stephens or clients of other advisory representatives of Stephens or Stephens, its principals, employees, affiliates and their family members, sometimes hold, and sometimes engage in transactions in, securities purchased or sold for the client or about which Stephens gives or has given client advice. The client’s account may purchase as investments securities of companies with which Stephens or its affiliates maintain investment banking relationships or other relationships or securities of companies in which Stephens or its affiliates have an ownership or other investment interest.  Subject to applicable law, Stephens sometimes pays fees to, and/or shares revenues with, affiliates or non- affiliates in connection with referrals for investment advisory accounts. For additional information regarding referral fees, please see Item 9.  Stephens, or its affiliates, may provide more than one type of service to the client (or a related organization), including (but not limited to), investment management services, investment advisory services, financial advisory services, underwriting services, placement agency services, investment banking services, securities brokerage services, securities custodial services, insurance agency services, insurance brokerage services, administrative services or other services, or any combination of services, all on such terms as may be agreed between Stephens (or its affiliate) and the client (or its related organization).  Other divisions and other advisory representatives of Stephens perform investment advisory services for clients other than the client and such other divisions or other advisory representatives of Stephens give advice or take action with respect to other clients that is similar to or different from the advice given or action taken for the client’s account, in terms of securities, timing, nature of transactions and other factors. Stephens will, to the extent practicable, attempt in good faith to allocate investment opportunities among its clients, including the client, on a fair and equitable basis. However, other divisions and other advisory representatives of Stephens will not undertake to make any recommendation or communication to client with respect to any security which such other divisions or advisory representatives may purchase or sell (either as principal or for any other client’s account) or recommend to any other client, or in which such other divisions or advisory representatives or their respective principals, employees, affiliates or their family members, may engage in transactions.  Both advisory and brokerage clients of Stephens have the ability to borrow money against the collateral value of their accounts with non-purpose loans arranged through Stephens with third party banks. Stephens receives an administrative fee which is paid by the third party banks in an amount which varies but can be up to 1.35% of the monthly outstanding balance of the client’s loan. Part of the fee is passed along to the IAR, and this can create a conflict of interest. Since Stephens has not compared rates available elsewhere, clients may be able to obtain lower interest rates on their loans through other banks.  Stephens and Pershing and IntraFi Network LLC receives fees and benefits for services provided in connection with the Bank Sweep Program. Stephens offers the Bank Sweep Program as a service and is not obligated to offer you this or any sweep product or to make available to you a sweep product that offers a rate of return that is equal to or greater than other comparable products or investments. Stephens has an economic incentive to make available to our clients sweep options that are more profitable to us than other sweep options. ADV Part 2A Appendix 1 March 31, 2025 21  Each Bank will pay Stephens a fee equal to a percentage of the average daily deposit balance in your Deposit Accounts at the Bank. Because the Banks pay different amounts, the compensation paid to Stephens will vary from Bank to Bank. Because the interest rates paid to clients are subject to tiers based on the aggregate value of accounts within the client’s Household Balance, Stephens’ compensation rate is higher on client’s cash in lower interest rate tiers and lower on client’s cash balances in higher rate tiers. Stephens may reduce its fee and may vary the amount of the reductions between clients. The interest rate applicable to your Deposit Account is determined by the amount of interest participating banks are willing to pay on the aggregate balance of the deposits minus: (i) the fees paid to Intrafi Network LLC, as administrator, (ii) the fees paid to Pershing for its services, and (iii) the fees paid to Stephens. Stephens retains and exercise the right to negotiate its own fee and may reduce or increase its fee. Because an increase in fees to Stephens reduces the effective amount of the interest rate that is ultimately paid to customers, Stephens has a conflict of interest with regard to the Bank Sweep Program. The tier applicable to your Deposit Accounts is determined based on your Household Balance as of the first business day following the fifteenth (15th) of the month. Stephens charges advisory accounts an investment advisory fee based on a percentage of client assets. In computing your investment advisory fee, cash balances in the Bank Sweep Program are included in the assets of your account when calculating the investment advisory fee earned by Stephens for management of your account. Therefore, Stephens is paid both its fee from the Banks on the Bank Sweep Program balance in your account, and, in addition, Stephens earns an investment advisory fee for your total balances in your account, including your balance in the Bank Sweep Program. This creates a conflict of interest, as Stephens earns more from Bank Sweep Program balances in investment advisory accounts than it would if such balances were held outside of the Bank Sweep Program or outside of the investment advisory account entirely, creating an economic incentive for Stephens to retain advisory assets in cash in the Bank Sweep Program. Your IAR does not receive a portion of the fee paid to Stephens by the Banks. • The Stephens Investment Banking department may introduce its clients, prospective clients, or affiliates thereof, to Stephens IARs. This introduction is done in Stephens’s capacity as a registered broker-dealer, and not as a registered investment advisor. If the introduction results in a new account relationship, then for a period of years as portion of the net revenue from such account is allocated to the Investment Banking department as a referral fee. Such revenue is considered, along with other factors, in the determination of compensation for the introducing investment banker(s). This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. Conflict of Interest with Personal Trading and Client Trades To minimize potential conflicts of interest, advisory personnel who determine or approve what recommendations will be made for client accounts will not participate in Stephens’ proprietary trading activities and will not know what trading strategies are employed for its proprietary accounts. It should be noted, however, that Stephens allows purchases to be made in the marketplace by its employees of securities owned by any client account, provided that such purchases are made in amounts consistent with the normal investment practice of the person involved. Such purchases must be made after the investment advisory accounts managed by such employee (or in the management of which such employee participates) has completed its transactions in such securities. Under certain circumstances, employee transactions may be permitted prior to full completion of investment advisory division’s transactions. Such exceptions require prior approval of the Chief Compliance Officer or his designee and will only be granted after considering factors such as the time element involved in filling the order, market considerations, etc. Stephens Personal Trading Stephens’ personnel may not participate in IPOs. All employees are required to maintain their personal accounts and accounts in which they have a beneficial interest at Stephens unless the account has been specifically exempt in writing from this requirement. Stephens’ employees are required to provide copies of all of their trade confirmations and brokerage account statements to Stephens’ Compliance Department in order to permit the monitoring of compliance with personal trading policies and restrictions. Additionally, IARs are required to report all personal securities transactions no less than quarterly. Stephens’ Code of Ethics requires employees to report violations of the Code to Stephens Chief Compliance Officer. Portfolio Management Description of Advisory Services ADV Part 2A Appendix 1 March 31, 2025 22  Stephens’ investment advisory services seek to tailor an investment program for the financial goals and objectives of a particular client. When we are engaged as an investment advisor, the client typically pursues one or more of our investment strategies. Clients may impose reasonable investment restrictions on their accounts, such as restrictions on investing in particular securities or types of securities or restrictions on investing in particular industries. Except with respect to the payment of the fees or service charges or for correction of errors, Stephens is not authorized to withdraw or transfer any money, securities, or property out of a client’s account, without authorization from the client. Client acknowledges and understands that brokerage or securities transaction execution services provided by any person or entity other than Stephens or Pershing are separate from and in addition to the wrap fee for the account. Additionally, regular service charges shall apply to client’s account for brokerage services other than securities execution services provided by Stephens. Stephens and its affiliates perform advisory and/or brokerage services including investment reporting for various clients, and Stephens gives advice or takes actions for other clients that differ from the advice given or the timing or the nature of any action taken for your account. In addition, Stephens may, but is not obligated to, purchase or sell or recommend for purchase or sale any security which Stephens or any of its affiliates may purchase or sell for their own accounts or the account of any other client. Stephens and Pershing will not charge commissions on securities transactions that are executed through Stephens or Pershing for these accounts. Your account is responsible to pay any commission charges imposed by any other brokerage firm on any securities transactions executed through any other brokerage firm, and such charges are in addition to the wrap fee and any other applicable charges incurred by your account. By executing trades through Stephens with Pershing, your account might forego benefits, such as participation in block trades or negotiated transactions that might be available through other brokerage firms. For ERISA and IRA accounts, when Stephens provides non-discretionary investment advice to the client regarding such an account, we are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we are compensated can create conflicts of interest, so we have established procedures which require us to act in the client’s best interest and not put our interest ahead of the client’s. about the Bank Sweep Program please review these important disclosures Stephens Insured Bank Sweep Program Stephens makes available to clients whose accounts are custodied at Pershing the opportunity to participate in the Bank Sweep Program. In this program all of the uninvested cash in a client’s account is automatically deposited, or “swept” into FDIC insured, interest-bearing deposit accounts at one or more banks which participate in the Bank Sweep Program. None of the banks participating in the Bank Sweep Program are owned by or affiliated with Stephens. For more information at www.stephens.com/investment-disclosures/ which are incorporated by reference into this Form ADV Part 2A. Stephens offers the Bank Sweep Program as a service and is not obligated to offer this or any sweep product or to make available to a sweep product that offers a rate of return that is equal to or greater than other comparable products or investments. The interest rates paid on Deposit Accounts at a bank may be higher or lower than the interest rates available to depositors making deposits directly with the bank or other depository institutions in comparable accounts and for investments in other cash equivalent investments through Stephens. The Bank Sweep Program is not available to ERISA plans with accounts at Stephens such as employee benefit plans, retirement plans, defined contribution plans, defined benefit plans, (collectively, “ERISA accounts”) or to traditional and rollover IRA accounts, Roth, SEP, SIMPLE and inherited IRAs; Keogh plans; and Coverdell education savings accounts. The Bank Sweep Program for your account should not be viewed as a long-term investment option. If you desire, as part of an investment strategy or otherwise, to maintain a cash position in your account for other than a short period of time and/or are seeking the highest yields currently available in the market for your cash balances, please contact your FC to discuss investment options that are available outside of the Bank Sweep Program to help maximize your return potential consistent with your investment objectives, liquidity needs and risk tolerance. Please note, however, that available cash accumulating in your account will not be automatically swept into any investment you purchase outside of the Bank Sweep Program. Nothing obligates you to participate in the Bank Sweep Program. You may receive a higher rate of return through products offered outside the Bank Sweep Program, including Money Market Funds offered through your account with Stephens and Pershing. ADV Part 2A Appendix 1 March 31, 2025 23  Each Deposit Account constitutes a direct obligation of the Bank and is not directly or indirectly an obligation of Stephens or Pershing. Stephens and Pershing do not guarantee in any way the financial condition of the Banks or the accuracy of any publicly available financial information concerning such Banks. You are responsible for monitoring the total amount of deposits that you hold with any one Bank, directly or through an intermediary, in order for you to determine the amount of deposit insurance coverage available to you on your deposits. Stephens and Pershing are not responsible for any insured or uninsured portion of a Deposit Account. Restrictions In SCM programs, you can impose reasonable restrictions on account investments. For example, you may restrict Stephens from buying specific securities, a category of securities (e.g., tobacco companies) or mutual funds and Exchange Traded Funds (“ETF”) (collectively known as “Funds”) shares. If you restrict a category of securities, we will determine which specific securities fall within the restricted category. In doing so, we rely on outside sources (e.g., standard industry codes and research provided by independent service providers). Any restrictions you impose on individual securities have no effect on Fund holdings since Funds operate in accordance with the investment objectives and strategies described in their prospectuses. Wrap Fee Programs In addition to other indications of individual ownership, including the right to withdraw, hypothecate, vote, or pledge securities held in the wrap fee client’s account, a wrap fee advisory client has the ability to place reasonable limitations and/or restrictions on the investments in their portfolio. Where restrictions are imposed, Stephens will not knowingly make any discretionary investments of the client’s portfolio assets in violation of these restrictions, but the investment performance of the client’s account will likely differ (positively or negatively) from other clients following a similar investment strategy, that is not subject to the same restrictions. The minimum account size for wrap fee programs vary from program to program, and a person considering a wrap fee program should review the ADV for details regarding the operation of the program, its risks, fees, and other charges. The entire wrap fee is paid to Stephens for its services relating to each wrap fee account. In determining the suitability of an investment strategy for a particular wrap fee program client, we rely on the information provided by the client regarding the objectives of the client for each account. This information comes from, among other sources, personal interviews with the client and written questionnaires completed by the client and other communications with the client or its representative regarding the client’s situation, investment objectives, risk tolerances and investment restrictions, if any. Our strategies are not appropriate for all investors, and investors should only invest a portion of their portfolio in these Programs. In certain Programs we have the discretionary authority to determine the securities, and the amount of securities, to be bought and sold for our clients without obtaining specific client consent. The discretionary authority regarding investments may, however, be subject to certain reasonable restrictions and limitations placed by the client on transactions in certain types of securities or industries or to restrictions or limitations imposed by applicable regulations. Performance-Based Fees and Side-By-Side Management Stephens typically charges clients an investment advisory fee based on the value of the assets in the client’s account. On occasion, Stephens enters into performance fee arrangements with appropriate clients as discussed below. Only certain clients qualify for performance fee arrangements which compensate Stephens based, in part, on the performance of the client’s account. All fees are negotiable and vary depending on the size of the investment, the nature of the services to be rendered by Stephens to the client, and other factors. Performance fees are typically invoiced annually. Stephens only enters into performance fee arrangements with certain clients which are eligible to enter into these arrangements as defined in Rule 205-3 under the Investment Advisers Act of 1940 and in accordance with the requirements set forth in applicable laws, rules and regulations, and these arrangements are negotiated with the client on an individualized basis. The performance fee arrangement could create an incentive for Stephens to seek to maximize the investment return by making investments that are subject to greater risk, or are more speculative, than would be the case if Stephens’ compensation were not based upon the investment return or could create an incentive for Stephens to seek to limit investment returns by pursuing investments with reduced risk. With a performance fee arrangement Stephens’ fee is, in part, contingent upon the returns on the client’s assets, which are computed based upon unrealized and realized appreciation or depreciation of client’s assets. This gives Stephens an incentive to favor performance with investment opportunities and therefore creates a conflict for Stephens. Accounts participating in a performance fee arrangement may pay Stephens more compensation, or less compensation, when compared to standard fee rates. Performance fee arrangements are not available for all investment accounts and ADV Part 2A Appendix 1 March 31, 2025 24  must be approved by Stephens on a case-by-case basis. Performance fee rates are negotiable. A client may negotiate a base fee rate, performance fee rates, an index to be used to calculate the performance fee, or the use of no index in calculating the performance fee. Any performance fee that Stephens charges is intended to comply with Rule 205-3 and other applicable requirements under the Investment Advisers Act of 1940 (the “Adviser’s Act”). Stephens has an incentive to favor accounts which it charges a performance fee over other types of client accounts by allocating more profitable investments to performance fee accounts or by devoting more resources toward the accounts’ management. Stephens seeks to mitigate the potential conflicts of interest which arise from managing accounts that bear a performance fee through its policies and procedures, including those related to investment allocation, and by complying with the provisions of Rule 205-3 as stated above. Stephens has discretion not to accept these arrangements. Methods of Analysis, Investment Strategies and Risk of Loss We utilize street and independent sources for our research, but it is not the sole basis of our investment decision-making process. Other sources of information we utilize can include industry data obtained from subscription services, company filings, street research and models. We utilize these services for real-time news and pricing. We also utilize other independent research sources for quantitative reports that measure such things as price changes, growth rates, profitability, valuation, earnings surprises and earnings revisions. These quantitative reports are used to help identify new securities that meet our investment criteria and to monitor existing holdings. Under certain Programs, such as SCM Discretionary, Spectrum Program and SCM Fixed Income, your IAR may currently provide investment advisory services for your discretionary portfolio. Your IAR has the flexibility to adapt strategies to a changing financial environment while keeping your goals and objectives in mind. Investing in securities involves risk of loss that clients should be prepared to bear. The material risks associated with our strategies are: Alternative Investments - Investing in alternative investments can be highly illiquid, is speculative and not suitable for all investors. Certain alternative investment products place substantial limits on liquidity and the redemption rights of investors, including only permitting withdrawals on a limited periodic basis and with a significant period of notice and may impose early withdrawal fees. Investing in alternative investments is intended for experienced and sophisticated investors only who are willing to bear the high economic risks of the investment. Investors should carefully review and consider potential risks before investing. Certain of these risks include: loss of all or a substantial portion of the investment due to leveraging, short selling, or other speculative practices; lack of liquidity, in that there may be no secondary market for the fund and none expected to develop; volatility of returns; restrictions on transferring interests; potential lack of diversification and resulting higher risk due to concentration of trading authority when a single advisor is utilized; absence of information regarding valuations and pricing; complex tax structures and delays in tax reporting; less regulation and higher fees than mutual funds; and advisor risk. Alternative investment products typically have higher fees (including multiple layers of fees) compared to other types of investments. Individual funds will have specific risks related to their investment programs that will vary from fund to fund. Debt Obligations - Investing in debt (bond) obligations entails additional risks, including interest rate risk such that when interest rates rise, the prices of bonds and the value of bond funds shares can decrease and the investor can lose principal value. Equity Market Risk – Overall stock market risks affect the value of the investments in equity strategies. Factors such as U.S. economic growth and market conditions, interest rates, and political events affect the equity markets. Foreign Debt Obligations - Investing in foreign debt obligations entails additional risks, including those related to regulatory, market or economic developments, foreign taxation and less stringent investor protection and disclosure standards. Foreign Securities - Investing in foreign securities presents certain risks that are not present in domestic securities. For example, investments in foreign and emerging markets present special risks including currency fluctuation, the potential for diplomatic and political instability, regulatory and liquidity risks, foreign taxation and differences in auditing and other financial standards. In addition to the greater exposure to the risks of foreign investing, emerging markets present considerable additional risks, including potential instability of emerging market countries and the increased susceptibility of emerging market economies to financial, economic and market events. Money Market Risk - An investment in a Money Market Fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although the fund seeks to preserve the value of your ADV Part 2A Appendix 1 March 31, 2025 25  investment at $1.00 per share, it is possible to lose money by investing in the fund. Yields will vary. Yield quotations more closely reflect the current earnings of the fund than the total return. Management Risk - Our judgments about the attractiveness and potential appreciation of a particular asset class, mutual fund or individual security may be incorrect and there is no guarantee that individual securities will perform as anticipated. The price of an individual security can be more volatile than the market as a whole and our investment thesis on a particular stock may fail to produce the intended results. Options Risk- Options involve risk and are not suitable for all investors. Small Cap and Mid Cap Company Risk - Investing in small cap and mid cap issuers involves a significantly greater risk than investing in larger, more established companies. The daily trading volume for small cap and mid cap issuers can be much lower than for more widely held, established companies. There may be periods when it is difficult to invest in or liquidate portfolio investments for our various investment strategies. This is particularly the case when breaking news on a company occurs or when significant market forces and events occur. In addition, small and mid-cap companies are more vulnerable to economic, market and industry changes. Because smaller companies often have limited product lines, markets or financial resources, or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than larger capitalization companies. Investors should only invest a portion of their total portfolios in these securities, and investors should be prepared to lose their entire investments. Certain Risks Associated with Cybersecurity. With the increased use of technologies to conduct business, investment advisors, including Stephens rely in part on digital and network technologies (collectively, “cyber networks”). These cyber networks are susceptible to operational, information security and related risks and can be at risk of cyber-attacks. Cyber-attacks could seek unauthorized access to cyber networks for the purpose of misappropriating sensitive information, corrupting data, or causing operational disruptions. Cyber-attacks can potentially be carried out against the issuers of securities you have invested in, against third party service providers, or against Stephens itself by persons using techniques that range from efforts to circumvent network security, overwhelm websites, and gather intelligence through the use of social media in order to obtain information necessary to gain access to cyber networks. Although cyber-attacks potentially could occur, Stephens and Pershing maintain an information technology security policy and technical and physical safeguards intended to protect the confidentiality of internal data. Bank Sweep Program If you have on deposit through the Bank Sweep Program an amount of cash that exceeds the number of Banks multiplied by $250,000, the balances in excess of this amount will not be insured by the FDIC. In the event of a failure of a bank participating in the Bank Sweep Program, there may be a time period during which you may not be able to access your cash. If you have cash at a bank outside the Bank Sweep Program, this may negatively impact the availability of FDIC insurance for the total amount of your funds held within and outside the Bank Sweep Program. You are responsible for monitoring the total amount of deposits that you hold with any one Bank, directly or through an intermediary, in order to determine the extent of FDIC insurance coverage available to you on your deposits, including the Deposit Accounts. IARs or Stephens Acting as Portfolio Manager SND- Non Discretionary, Stephens Spectrum 401k, HMT and PMT In this program, IARs or supervised persons of Stephens do not act with discretion. SCMD – Discretionary, SSP and SCM-FIS In connection with the programs, the IAR has discretionary authority to manage the assets in the account and authorizes Stephens to make such trades of securities or other property in the exercise of its discretion which it or the IAR determines to be appropriate based upon the investment objectives of the client. Investment Advisory Proxy Policies For proxy voting directed by Stephens, it is Stephens’ policy to vote proxies on securities that are owned in an account and held in custody by Pershing for the account and to utilize Investment Advisory policies and procedures, which are reasonably designed to vote client securities in the best interests of the client and to address how potential conflicts of ADV Part 2A Appendix 1 March 31, 2025 26  interest are handled. Stephens’ proxy voting policy is to vote in favor of actions recommended by the issuer’s Board of Directors, unless the IAR disagrees with the proposed action and elects to vote the shares against the recommendation of the Board of Directors. If there is not a Board of Directors recommendation on a proposed action, then the IAR will determine whether to vote for, against or abstain. If the client chooses to custody their securities away from Pershing it will be the responsibility of the client to vote or to arrange for the voting of their proxies. SND – Non Discretionary, Stephens Spectrum 401k, HMT and PMT Stephens will not take any action with respect to the voting of proxies solicited by or with respect to the issuers of securities in which assets of the client may be invested from time to time, except to provide proxy materials to client. Stephens will have no power, authority, responsibility or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in the client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. SCMD - Discretionary It is Stephens’ policy to vote proxies on securities that are owned in a discretionary account and held in custody for the account by Stephens and to utilize Investment Advisory policies and procedures, which are reasonably designed to vote client securities in the best interests of the client and to address how potential conflicts of interest are handled. Conflicts of Interest On an annual basis Stephens will disclose to affected clients any identified potential material conflicts of interest by providing a list of said conflicts electronically or by mail. Where Stephens has identified a specific potential material conflict of interest relating to one or more matters to be voted on by shareholders, Stephens: (1) will notify affected clients of the potential conflict of interest, (2) will disclose how the proxy will be voted absent a voting direction from the client, and (3) will give affected clients the opportunity to vote the proxy themselves. Stephens will maintain a record of the voting resolution of any conflict of interest. Corporate Actions and Other Matters From time to time there may also be a variety of corporate actions or other matters for which shareholder action is required or solicited and with respect to which Stephens may take action that it deems appropriate in its best judgment except to the extent otherwise required by agreement with the client. These actions include, for example and without limitation, responding to tender offers or exchange offers, bankruptcy proceedings and proposed class action settlements. However, Stephens will have no power, authority, responsibility or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in the client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. Investment Advisory Proxy Voting Procedures Stephens’ procedures to implement the Firm’s proxy voting policy, is as follows:  Proxy materials are received on behalf of clients in Stephens’ Reorganization Department (“Reorg Department”).  A Proxy Voting Notice which includes a link to the proxy voting materials is sent by the Reorg Department via e-mail to the respective advisory area. This Proxy Voting Notice will be used to instruct the Reorg Department as to how to vote the shares.  Stephens will vote the proxy through the Reorg Department in accordance with applicable voting guidelines, either by electronically voting or by mailing the proxy in a timely and appropriate manner.  Unless the responsible IAR or Investment Committee loses confidence in management of the issuer or the client directs the vote, Stephens will vote the shares as recommended by the Board of Directors of the issuer;  If there is not a Board of Directors recommendation on a proposed action, then the IAR will determine whether to vote for, against or abstain. ADV Part 2A Appendix 1 March 31, 2025 27  Proxy Information Stephens will make available information of the firm’s proxy voting policy and procedures including information regarding how Stephens voted proxies, if requested. In response to any request as to how the client’s proxies were voted, the Chief Compliance Officer or his designee will provide the information to the client. Item 7: Client Information Provided to IARs and Sub-Advisors Stephens’ advisory programs are available to individuals, banks, foundations, pension and profit sharing plans, trusts, IRAs, endowments, corporations, partnerships and other entities requiring investment advisory services. Stephens’ investment advisory services business is focused on high net worth individuals, foundations and businesses. We provide investment advice to individuals, trusts, to boards and retirement systems for various governmental pension and retirement plans, to corporate pension and retirement plans, to various foundations and private entities. Our investments include equity securities, fixed income securities, mutual funds, exchange-traded securities and other types of securities. Information about the client is communicated to the IAR on the initial opening of the advisory account. An Agreement is completed reflecting information provided by the advisory client, and maintained by Stephens. The New Account Form contains account name and address, investment objectives and specific financial information. Advisory account information is updated upon notification from the advisory client of any material changes and noted within the client file. The IAR assigned to advise the account has access to the client’s data maintained by Stephens. Item 8: Client Contact with IARs Client Meetings The IAR assigned to the client’s account is the client’s primary point of contact with Stephens. IARs must offer to discuss or meet no less frequently than annually with advisory clients. Clients are encouraged to contact the IAR at any time if they have questions or would like to have additional discussions or meetings. If you have experienced any changes regarding your financial situation, investment objectives or risk tolerance, please contact your IAR to see if any adjustments are necessary to your investment strategy. Sub-Advisor Contact Although clients are not prohibited from directly contacting Sub-Advisors in the SCM programs, clients are encouraged to use their IAR as their primary contact. Item 9: Additional Information Disciplinary Information Stephens voluntarily participated in the Securities and Exchange Commission’s Share Class Selection Disclosure Initiative, and on March 11, 2019 the SEC entered a Cease and Desist Order against Stephens in which Stephens neither admitted nor denied the allegations of the SEC’s Order. The Order alleged that Stephens did not fully disclose conflicts of interest related to the selection of mutual fund share classes for its advisory clients, and that Stephens purchased, recommended or held mutual fund share classes for client accounts which paid Stephens 12b-1 fees when less expensive share classes of the same funds were available which did not pay Stephens these 12b-1 fees. The Order directed Stephens to Cease and Desist from committing or causing any violations and any future violations of Sections 206(2) and 207 of the Investment Advisers Act of 1940 and ordered that Stephens be censured and pay disgorgement and prejudgment interest to advisory clients who held these more expensive mutual funds share classes in their advisory accounts. (IA Release No. 40-5196) In its capacity as a broker-dealer, Stephens has been subject to legal or disciplinary events in the ordinary course of its business, such as regulatory sanctions relating to compliance with broker-dealer trade reporting requirements and other regulatory actions. Affiliations Stephens, from time to time, enters into arrangements with other broker-dealers, investment advisors or other persons whereby such parties refer clients seeking advisory services to Stephens. For additional information regarding Stephens’ affiliations, please see Item 6 “Conflicts of Interest above”. Code of Ethics ADV Part 2A Appendix 1 March 31, 2025 28  Stephens has adopted an Investment Advisory Code of Ethics (“Code”), which defines the requirements and expectations for the business conduct of all of its Investment Advisory employees, including employees of Stephens. Furthermore, all Stephens’ employees are expected to adhere to Stephens’ Mission and Values Statement and Code of Professional Conduct. The fundamental position of Stephens is that all aspects of its business are to be conducted in an ethical and legal manner in accordance with federal law and the laws of all states where the investment advisory divisions do business. In accordance with that position general principles apply:  The interests of Stephens’ clients are our first consideration. Any personal securities transaction, which would be detrimental or potentially detrimental to any client account and any personal securities transaction, which is designed to profit by the market effect of any client account, must be avoided.   All personal securities transactions should be conducted in such a manner as to be consistent with the Code and to avoid actual or potential conflicts of interest or abuse of a Stephens’ employee’s knowledge of client information or client transactions. Investment advisor personnel should not take inappropriate advantage of their positions. Information concerning the identity of security holdings and financial circumstances of clients is confidential. Independence in the investment decision-making process is paramount.  Accordingly, there are certain standards of conduct, which Stephens investment advisory employees follow to reduce potential conflicts with the interests of our clients. Stephens will provide a copy of the Code to any client or prospective client upon request. Review of Accounts Supervision & Reviews Primary responsibility for the supervision of advisory accounts lies with the SCM Supervisory Principals. SCM Supervisory Principals conduct periodic reviews of activity in selected advisory accounts, considering suitability of transactions and general performance. SCM Supervisory Principals may also consider levels of activity, timing of transactions, transactions in restricted securities, profitability, concentration in one security and individual objectives and needs of the client based on information provided by the client. In addition to the monthly reviews, designated principals at Stephens’ home office make quarterly reviews of the investment performance and investment strategy of selected accounts. The reviewers may refer accounts to the Compliance Department for further analysis if necessary. Reviewers are not assigned accounts by any formula or numerical standard. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b-1 fees are received on client advisory holdings, these will be rebated to the advisory client. Oversight The Spectrum Investment Committee and the SCM-FIS Investment Committee are each responsible for reviewing their respective client accounts and coordinating with IARs regarding adherence to the client’s investment objectives with respect to allocation and performance. The committees rely on internal reports in their overall review process. When Stephens executes a transaction for you through a Pershing order execution system, you will receive written or electronic confirmation of the transaction which provides information regarding the transaction. You may elect to receive these quarterly. You will also receive a written or electronic monthly account statement if you had activity in your account during the month which will detail the activity and the positions in your account. If you have not had any activity during the month and you have positions in your account, you will receive a written or electronic quarterly account statement which details the positions in your account. You may waive the receipt of account statements or confirmations after each trade in favor of e-delivery via https://stephensaccess.netxinvestor.com/web/stephens/login. You may also receive mutual fund prospectuses, where appropriate. Client Referrals and Other Compensation Neither Stephens nor any of our employees receives any sales awards or other prizes from any non-affiliated outside parties for providing investment advice to our clients. Stephens may enter into referral arrangements with its affiliates or between divisions of the Firm. This includes referrals to Stephens of prospective clients seeking investment advisory services. If the referral results in a new account relationship, then a portion of the net revenue from such account is paid to such entity or division as a referral fee, and such entity or division may pay some portion of the fee to the referring person. This arrangement is disclosed to the client ADV Part 2A Appendix 1 March 31, 2025 29  and does not result in any additional fees or charges to the client. Such arrangements are conducted in accordance with the Marketing Rule, as applicable, and the Advisers Act generally. IARs are eligible to receive referral fees for referring eligible clients to the Stephens Investment Banking division. For eligible investment banking referrals, referring parties are eligible to receive compensation as a percentage of net income earned by Investment Banking. Therefore, IARs are incentivized to refer clients to the Investment Banking division. Any such compensation to the IAR is at the discretion of the Firm. Financial Information Stephens does not require or solicit prepayment of more than $1200 in fees per client six months or more in advance and, thus, has not included a balance sheet of its most recent fiscal year. Stephens is not aware of any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to our clients. Who to Contact We are pleased to have an opportunity to serve as your IAR. If you have any questions about the information contained in this brochure or about any aspect of the services we provide, please do not hesitate to call Stephens at (877-891-0095). Clients often receive this information by electronic delivery. The Stephens ADV and additional brochures are available at www.stephens.com/investment-disclosures/. To access your IAR's SEC Advisor Biography, go to www.stephens.com , use the search bar in the top right corner of the home page and search by your IAR's name. SEC Advisor Biographies are also available in the "Our Team" section and are there for your review. ADV Part 2A Appendix 1 March 31, 2025 30  Definitions and Professional Designation Qualifications Accredited Investment Fiduciary® (AIF®) The Accredited Investment Fiduciary (AIF®) Designation is a professional certification that demonstrates an advisor or other person serving as an investment fiduciary has met certain requirements to earn and maintain the credential. The purpose of the Accredited Investment Fiduciary (AIF®) Designation is to assure that those responsible for managing or advising on investor assets have a fundamental understanding of the principles of fiduciary duty, the standards of conduct for acting as a fiduciary, and a process for carrying out fiduciary responsibility. The AIF® training curriculum is offered in distance education or a blended learning option to suit each Candidate's needs. Fi360’s Prudent Investment Practices cover four Steps (domains), twenty-one Practices (tasks), and seventy-nine Criteria that an investment fiduciary is expected to be able to perform. After passing the exam, a Candidate wishing to file for the AIF® designation must submit the accreditation application and accreditation fee. Six Hours of annual continuing education is required, a minimum of four of which must be delivered by Fi360 or one of Fi360's approved CE providers. Accredited Wealth Management AdvisorSM (AWMA® ) Individuals who hold the AWMA® designation have completed a course of study encompassing wealth strategies, equity-based compensation plans, tax reduction alternatives, and asset protection alternatives. Additionally, individuals must pass an end-of-course examination that tests their ability to synthesize complex concepts and apply theoretical concepts to real-life situations. All designees have agreed to adhere to Standards of Professional Conduct and are subject to a disciplinary process. Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standards of Professional Conduct and complying with self-disclosure requirements. The Chartered Financial Analyst (CFA) The CFA designation is awarded to investment professionals who have successfully completed the requirements set forth by the CFA Institute. CFA Institute has a long-standing history of and commitment to establishing a broadly accepted ethical standard for calculating and presenting investment performance based on the principles of fair representation and full disclosure. The goals in developing and evolving the Global Investment Performance Standards (GIPS) are to establish them as the recognized standard for calculating and presenting investment performance around the world and for the GIPS standards to become a firm’s “passport” to market investment management services globally. The CFA Institute is an international non-profit organization whose stated mission is to promote and develop a high level of educational, ethical and professional standards in the investment industry. To be eligible for the CFA designation, candidates must pass 3 examinations that test the academic portion of the CFA program, possess a bachelor’s degree from an accredited educational institution or equivalent, and have 48 months of acceptable professional work experience. The CFA curriculum includes the following subject areas: Ethical and Professional Standards; Quantitative Methods (such as the time value of money, and statistical inference); Economics; Financial Reporting and Analysis; Corporate Finance; Analysis of Investments (such as stocks and bonds); and Portfolio Management and Analysis (asset allocation, portfolio risk, and performance measurement). CERTIFIED FINANCIAL PLANNER™ (CFP®) To earn the CFP® designation, an individual must complete a college-level course of study addressing the financial planning subject areas determined by the Certified Financial Planner Board of Standards, Inc. (“CFP Board”), pass a comprehensive two-day examination developed by the CFP Board and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university) and demonstrate three years of full-time work experience in financial planning or a related field. CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning. Once the CFP® has attained the CFP certification, they are require to complete 30 credit hours of continuing education accepted by CFP Board every two years, including 2 hours of CFP Board- approved ethics continuing education. Chartered Financial Consultant® (ChFC®) The ChFC® Program offers comprehensive education in the essentials of financial planning, including insurance, taxation, retirement, and estate planning. It also addresses advanced areas such as behavioral finance, non-traditional ADV Part 2A Appendix 1 March 31, 2025 31  family structures, and small business planning. There are no prerequisite courses required before you can begin the ChFC® Program, but to use the designation, you are required to have three years of full-time, relevant business experience and a high school diploma or the equivalent. To receive and maintain the ChFC® designation, you must agree to comply with The American College Code of Ethics and Procedures and participate in the annual Professional Recertification Program (PRP) to maintain the designation. Certified Investment Management Analyst (CIMA) The CIMA certification signifies that an individual has met initial and on-going experience, ethical, education, and examination requirements for investment management consulting, including advanced investment management theory and application. Prerequisites for the CIMA certification are three years of financial services experience and an acceptable regulatory history. To obtain the CIMA certification, candidates must pass an online Certification Examination. The Certification Examination is a five-hour examination and has 125 multiple-choice questions and 15 non-scored, pretest questions. Each examination item (question) is related to an area of work performed by an investment management consultant/advisor. The topics have been identified through a job analysis. All examination items are written in a four-option, multiple-choice format. CIMA designees are required to adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and Guidelines for Use of the Marks. CIMA designees must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through Investment Management Consultants Association (IMCA). Certified Pension Consultant (CPC) The Certified Pension Consultant (CPC) credential is conferred by ASPPA to benefits professionals working in plan administration, pension actuarial administration, insurance and financial planning. CPCs work alongside employers to formulate, implement, administer and maintain qualified retirement plans. The CPC is the capstone credential, or highest credential, currently conferred by ASPPA. To earn the CPC credential, you must successful complete various exams, verify a minimum of two years’ experience in the retirement plan industry, provide two letters of recommendation and apply for the ASPPA credentialed membership. All credentialed members must acquire 40 hours of continuing education (CE) credits (2 of which must be Ethics) in a two-year cycle and renew their ASPPA Membership annually to retain their credential(s). The Certified Portfolio Manager (CPM®) The Certified Portfolio Manager (CPM®) designation is a collaboration of the Academy of Certified Portfolio Managers and Columbia University. The academic component is designed to provide a deeper understanding of fundamental security analysis, asset allocation, and portfolio management concepts for financial services industry professionals managing discretionary portfolios. The curriculum encompasses eight core concepts: • Quantitative Methods • Financial Statement Analysis • Corporate Finance • Fixed Income Analysis • Equity Analysis • Fiduciary Responsibility • Derivatives • Qualifying for the CPM® designation The current criteria for applicant eligibility are any of the following (1) a certificate, diploma or academic degree providing evidence of a four-year undergraduate degree (2) 3 years of employment in the financial services industry and (3) letter of recommendation on behalf of the applicant who is employed in the financial services industry, written by a supervisor, where the credential requirements are desired for the training and development of the applicant. At the end of each calendar year, ACPM members are required to submit the following; Record of 20 completed continuing education hours. ACPM maintains a self-auditing continuing education policy. Answers to a series of Professional Conduct questions. Annual membership dues. All three items are due by December 31st of that calendar year. Certified Public Accountant (CPA) CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the ADV Part 2A Appendix 1 March 31, 2025 32  education, experience and testing requirements for licensure as a CPA generally include minimum college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting), minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA), and successful passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of continuing professional education (CPE) activities on an ongoing basis. Additionally, all American Institute of Certified Public Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct. Chartered Retirement Planning Counselor SM (CRPC®) The CRPC® is conferred by the College for Financial Planning. Individuals who hold the CRPC® designation have completed a course of study encompassing pre-and post-retirement needs, asset management, estate planning and the entire retirement planning process using models and techniques from real client situations. Designees renew their designation every two years by completing 16 hours of continuing education, reaffirming adherence to the Standard of Professional Conduct and complying with self-disclosure requirements. Chartered Retirement Planning Specialist SM (CRPS®) The CRPS® is conferred by the College for Financial Planning. Individuals who hold the CRPS® designation have completed a course of study encompassing the specialization in creating, implementing and maintaining retirement plans for businesses. They must pass an exam demonstrating their expertise. Successful applicants earn the right to use the CRPS designation with their names for two years. Designees renew their designation every two years by completing 16 hours of continuing education, reaffirming adherence to the Standard of Professional Conduct and complying with self-disclosure requirements. Qualified Plan Financial Consultant (QPFC) QPFC is the professional credential for financial professionals who sell, advise, market or support qualified retirement plans. The QPFC program provides an understanding of general retirement planning concepts, terminology, distinctive features of qualified plans and the role of retirement plan professionals. QPFC is for professionals with two to three years of retirement plan experience. A candidate will be expected to demonstrate a general proficiency of plan administration, compliance, investment, fiduciary, and ethics issues. The QPFC credential is available as an alternative to the CPFA® credential. The coursework and exam are the same for both credentials. Candidates must complete the NAPA CPFA® exam, agree to abide by the ARA Code of Professional Conduct, and apply for the credential. In order to maintain the credential, designees must complete 10 CE hours per calendar year, starting the year following when the designation was earned. ADV Part 2A Appendix 1 March 31, 2025 33 

Uniform Application for Investment Advisor Registration Stephens Inc. 111 Center Street Little Rock, AR 72201-4430 877-891-0095 Website: www.stephens.com Private Client Group (“PCG”) Programs Stephens Advisor Professional Wealth Management Stephens Managed Assets Program Stephens Unified Managed Account Stephens Allocation Strategies Stephens Retirement Solutions Stephens Retirement Access Stephens IA Consulting March 31, 2025 This wrap fee program brochure provides information about the qualifications and business practices of Stephens Inc. If you have any questions about the contents of this brochure, please contact us at 877-891-0095 or www.stephens.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Stephens Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. Stephens Inc. is a registered investment adviser with the United States Securities and Exchange Commission. Registration does not imply a certain level of skill or training. SEC File No: 801-15510 ADV Part 2A Appendix 1 1 March 31, 2025  Item 2: Material Changes This is an annual update to the Private Client Group wrap fee program brochure. This section identifies and discusses material changes since the last annual update dated March 28, 2024. For more details, please see the item in this brochure referred to in the summary below. Item 9 was updated to disclose: (i) payments employees of Stephens Inc. and its affiliates can receive for referring prospective clients seeking investment advisory services, and (ii) payments Financial Consultants and Investment Advisor Representatives are eligible to receive for making referrals to Stephens Inc.’s Investment Banking division. ADV Part 2A Appendix 1 2 March 31, 2025  Item 3: Table of Contents Uniform Application for Investment Advisor Registration .................................................... 1 Item 2: Material Changes ......................................................................................................... 2 Item 3: Table of Contents ........................................................................................................ 3 Item 4: Services, Fees and Compensation ............................................................................. 4 General Information on Services and Fees ........................................................................................................................................ 4 General Description of Programs and Services .................................................................... 7 Non-Discretionary Wrap Programs .................................................................................................................................................... 7 Discretionary Wrap Programs ............................................................................................................................................................ 7 Limited-Discretionary Wrap Programs ............................................................................................................................................... 9 Stephens IA Consulting ................................................................................................................................................................... 12 Retirement Advisory Programs – Non Discretionary ........................................................................................................................ 12 Financial Planning Services ............................................................................................................................................................. 13 Comparing Costs ............................................................................................................................................................................. 13 Additional Fees ................................................................................................................................................................................ 13 Compensation to the Financial Consultant ....................................................................................................................................... 20 Item 5: Account Requirements and Types of Clients ...........................................................21 Account Minimums .......................................................................................................................................................................... 21 Types of Clients ............................................................................................................................................................................... 21 Item 6: Portfolio Manager Selection and Evaluation ............................................................21 Selection and Review of Portfolio Managers and Funds for the Programs ....................................................................................... 21 Review of Portfolio and Performance ............................................................................................................................................... 23 Additional Reviews .......................................................................................................................................................................... 23 Conflicts of Interest .......................................................................................................................................................................... 24 Portfolio Management Description of Advisory Services .................................................................................................................. 28 Financial Consultants or Stephens Acting as Portfolio Manager ...................................................................................................... 33 Investment Advisory Proxy Policies ................................................................................................................................................. 34 Item 7: Client Information Provided to FCs and Sub-Advisors ............................................36 Our Advisory Programs ................................................................................................................................................................... 36 Item 8: Client Contact with FCs..............................................................................................36 Client Meetings ................................................................................................................................................................................ 37 Sub-Advisor Contact ........................................................................................................................................................................ 37 Item 9: Additional Information................................................................................................37 Disciplinary Information .................................................................................................................................................................... 37 Affiliations ........................................................................................................................................................................................ 37 Code of Ethics ................................................................................................................................................................................. 37 Review of Accounts ......................................................................................................................................................................... 38 Client Referrals and Other Compensation ........................................................................................................................................ 39 Financial Information ....................................................................................................................................................................... 39 Who to Contact ................................................................................................................................................................................ 39 Definitions and Professional Designation Qualifications ....................................................40 ADV Part 2A Appendix 1 3 March 31, 2025  Item 4: Services, Fees and Compensation Stephens Inc. ("Stephens") is an Arkansas corporation, which registered with the Securities and Exchange Commission (“SEC”) as a broker-dealer in September 1946. Stephens registered as an investment advisor with the SEC on September 19, 1980 and began providing investment advisory services at that time. Stephens is a full service broker-dealer and investment bank. In addition to being registered with the SEC, Stephens is a member of the Financial Industry Regulatory Authority (“FINRA”), the New York Stock Exchange, Inc. (“NYSE”), the NYSE American LLC (“NYSE-AMEX”) the Municipal Securities Rulemaking Board (“MSRB”), the Investors’ Exchange LLC (“IEX”) and the Securities Investor Protection Corporation (“SIPC”). Stephens derives greater revenues from its broker-dealer and investment banking activities than it derives from its investment advisor activities. Affiliates of Stephens are also separately engaged in financial services businesses, including merchant banking, insurance and investment advisory businesses. General Information on Services and Fees Investment Advisory Contract Entering into an advisory relationship with Stephens involves the execution of an advisory contract (“Advisory Contract” or “Contract”). The term of the Advisory Contract is generally for a period of one year beginning on the effective date of the contract and is automatically renewed for successive additional one- year terms without further action. At the time of entering into such contract, the client has a right to terminate the contract without penalty within five (5) business days after the entering into the Contract and receive a full refund of any investment advisory fees paid to Stephens. At any time, either the client or Stephens may terminate the Contract without penalty, upon ten (10) days’ notice given in writing to the other party hereto. If the account is to be liquidated as the result of a termination notice, it is understood that Stephens may take up to five (5) trading days to effect liquidation following the date the liquidation request was received by Stephens. Proceeds will be payable to the client within ten (10) business days of termination. Upon termination of the Contract and payment of all sums, which may be owed under the contract, Stephens shall make such disposition of the managed securities or other property of the client held by it as may be directed by the client. The client will agree to pay Stephens the reasonable fees, costs and expenses incurred for such disposition and for collection, including attorney fees, of any unpaid balances under the Contract. At any time the client can terminate its Contract upon the terms without penalty. On June 5, 2019, the SEC issued its interpretation of the Standard of Conduct for Investment Advisers and rescinded certain previously issued no action letters. As a result of these changes, Stephens will not seek to enforce any provision of an investment advisory agreement with a retail investor which discharges Stephens or its agents from liability to the retail investor client. Termination of Contract Either Stephens or the client may terminate the Advisory Contract or may terminate an account managed pursuant to the Advisory Contract. Upon termination of the Advisory Contract, Stephens will convert your mutual funds to a non-advisory share class. Please see the section of this brochure entitled “Funds in Advisory Programs.” Termination of the Advisory Contract will not affect the liabilities or obligations of the parties arising from transactions initiated prior to termination. Termination of Retirement Account Contract Either Stephens or the client may terminate the Advisory Contract or may terminate an account managed pursuant to the Advisory Contract. Retirement accounts can be terminated by the client by simultaneously, (1) providing written notice of termination to Stephens and (2) providing Stephens with transfer instructions for the account to another custodian or instructions to distribute the account assets. ADV Part 2A Appendix 1 4 March 31, 2025  Distribution of account assets can create tax consequences. Fees You pay a single asset-based fee, charged monthly or quarterly, which covers the services provided by Stephens. Advisory fees apply to standard accounts and include investment advice, securities execution fees, certain custodial services, associated account reports and investment portfolio reports. This is a wrap fee. Advisory programs have different maximum annual fees. The maximum annual fee rate for the Stephens Allocation Strategies (“SAS”) program, Stephens Managed Assets Program (“MAP”) and Unified Managed Account (“UMA”) is 2%. The maximum annual fee rate for all other pre-paid wrap fee advisory accounts is 2.5%. A minimum fee is assessed per account. Fees are negotiable based on a number of factors including the type and size of the account and the range of services provided by the Financial Consultant (“FC”). In special circumstances, and with the client’s agreement, the fee charged to the client for an account may be more than the maximum annual fee stated in this section. Except with respect to the payment of applicable fees or service charges or other obligations owed to Stephens, or for correction of errors, Stephens is not authorized to withdraw or transfer any money, securities, or property out of a client’s account, without authorization from the client. On occasion, we enter into performance fee arrangements with appropriate clients. Performance fee arrangements compensate Stephens based, in part, on the performance of the client’s account. Only certain clients are eligible to enter into these arrangements under Rule 205-3 of the Investment Advisers Act of 1940, and Stephens has discretion not to accept these arrangements. When Fees are Paid and How Fees are Computed The fee is payable monthly in advance. All fees will be deducted from the client’s account, unless otherwise agreed in writing. For more information, contact your FC. If a percentage fee is used, the initial fee is calculated from the date the account is turned over for trading (“turnover date” of the advisory account) to the end of the then-current calendar month. The fee is obtained by multiplying the market value of eligible assets placed in the account by 1/12th of the applicable annual fee rate(s), prorated for the remaining percentage of the then-current calendar month. If a percentage fee is used, the fee for any subsequent monthly period will be the amount obtained by computing the market value of eligible assets in the portfolio as of the close of business on the last day of the previous month and multiplying the resultant market value by 1/12th of the applicable annual fee rate(s). A prorated fee will be charged when additional assets greater than $25,000 on a single deposit (or monthly aggregate) are placed in the account, in an amount determined by multiplying the market value of the additional eligible assets placed in the account by 1/12th of the applicable annual fee rate(s), prorated for the remaining percentage of the month. A prorated fee will be rebated when assets greater than $25,000 on a single withdrawal (or monthly aggregate) are withdrawn from the account, in an amount determined by multiplying the market value of the withdrawn assets from the account by 1/12th of the applicable annual fee rate(s), prorated for the remaining percentage of the month. If an account has a margin debit balance, the market value of the account used in computing Stephens’ fee is the total market value of all eligible assets, and it is not reduced by the margin debit balance. For example, an account with a total market value of $120,000 and a margin debit balance of $20,000 will have a net market value of $100,000. Stephens’ fee would be computed using the total market value of $120,000 times 1/12th of the applicable annual fee rate(s) adjusted by the time period. In the event a client’s account is closed before month-end, fees will be prorated as of the date of termination ADV Part 2A Appendix 1 5 March 31, 2025  Stephens may, in its sole discretion, pay all or a portion of the above stated fees to other parties involved in providing services with respect to client account(s) and as permitted by law. No party shall be compensated based on a share of capital gains or capital appreciation of funds or any portion of funds or other investments in the account. In addition to the wrap fee the client may also incur certain charges including, among others, the following types of charges; other transaction charges, service fees, wire fees and Individual Retirement Account (“IRA”) and Qualified Retirement Plan fees. Other parties receive a portion of these third-party fees. Further information regarding charges and fees assessed by other securities sponsors or Sub- Advisors is available in their appropriate ADV. The portion of the total fee that is typically paid to the FC is between 20% and 50%. Additional Fees Mutual Funds For any mutual fund investments Stephens’ clients invest in, fees are also charged by the mutual fund, as more fully described in the mutual fund’s prospectus. In discretionary accounts, Stephens has discretion to invest client funds in investment company securities in many of its advisory accounts. Individual mutual funds also pay fees to Stephens as a result of these investments. The existence of such applicable fees is disclosed in the Advisory Contract and such fees are more fully described in the fund prospectuses delivered to each client on initial investment. Past performance is no guarantee of future results. In the event 12b-1 fees are received on client holdings, these will be rebated to the advisory client. Is a Wrap Fee Arrangement for you? “Wrap fee programs” are programs in which the client pays a single fee for investment advisory services and related services, which may include executions, custody, and clearing charges. Certain additional fees may apply. See previous section entitled “Additional Fees” for more information. Stephens PCG Advisory Programs (“Programs”) may cost the client more or less than purchasing such services separately depending upon such factors as trading activity, account size and account minimums for non-wrap accounts. We encourage you to carefully consider your options in establishing or maintaining an advisory fee-based account. As a general matter, a fee-based advisory account approach may be considered appropriate for clients who rely on investment advice or investment management services or who engage in moderate to high levels of trading activity. A fee-based approach can be more economical for clients who engage in active trading, since the price per trade is reduced as the number of trades increases under a fee-based approach. However, fee-based advisory account arrangements may not be appropriate for clients who rely primarily on their own independent resources and judgments for making their investment selections and decisions and do not wish to purchase advisory services. Excluding the Stephens Retirement Access (“SRA”) and the Stephens Retirement Solutions (“RSP”) programs, clients who engage in a lower level of trading activity might prefer a traditional brokerage account with a commission payable on each transaction, particularly if the client typically does not utilize advisory services for trading decisions, as transaction cost savings might be realized in the context of a traditional pay-per- trade commission structure. However, retirement accounts are not available through Stephens as brokerage accounts. Typically, a portion of any revenue that the firm realizes in connection with an advisory account will be included in the calculation of the compensation to be paid by the firm to the FC; and, therefore, the FC will experience conflicts of interest similar to those experienced by the firm. Account Review The FC assigned to your account is your primary point of contact with Stephens. Your FC should offer to discuss or meet no less frequently than annually with you as an advisory client. Stephens encourages you to contact your FC at any time if you have questions or would like to have additional discussions or meetings. If you have experienced any changes regarding your finances, investment objectives or risk tolerance, please contact your FC to see if any adjustments are necessary to your investment strategy. ADV Part 2A Appendix 1 6 March 31, 2025  Confirmations, Account Statements and Performance Reviews In most cases, Pershing LLC (“Pershing”) is the custodian of your account and provides you with written or electronic confirmation of securities transactions, and account statements at least quarterly. You will also receive a monthly account statement if you have had qualifying activity in your account during the month which will detail the activity and the positions in your account. If you have not had any qualifying activity during the month and you have positions in your account, you will receive a quarterly account statement which details the positions in your account. You may waive the receipt of account statements or confirmations after each trade in favor of e-delivery www.StephensAccess.netxinvestor.com/. You may also receive mutual fund prospectuses, where appropriate. We will provide you periodic reviews of your account. These show how the account investments have performed on an absolute basis. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. General Description of Programs and Services Non-Discretionary Wrap Programs Stephens Advisor In the Stephens Advisor (“SA”) program, clients receive advice from the FC with individual attention to the client’s investment needs and objectives. FCs provide advice to clients utilizing strategies that include equity, fixed income, balanced, other investments, or a combination, in some cases that include alternative investments. FCs provide advice and make recommendations to clients at client’s request or as the FC deems appropriate. FCs in the SA program do not have discretionary authority over client assets, and all transactions in client assets are directed by client or client’s designee. Investment Services Stephens shall periodically provide you with investment advice, which can include recommendations regarding investing in available assets in a manner consistent with your investment objectives; and pursuant to your consent, which shall be obtained prior to each transaction, in order to accept transaction in the SA account. Stephens will not provide advice with respect to positions classified as unsupervised assets in the account. As part of the range of services available to clients in the SA program, advisory variable and fixed annuity contracts may be offered to appropriate retirement investors who are seeking certain income and death benefit solutions afforded by these products. Discretionary Wrap Programs In the following Programs, we have the discretionary authority to determine the securities and the amount of securities to be bought and sold for our clients without obtaining specific client consent. The discretionary authority regarding investments may, however, be subject to certain restrictions and limitations placed by the client on transactions in certain types of securities or industries or to restrictions or limitations imposed by applicable regulations. Stephens seeks to fully invest cash balances at all times, and many advised strategies include cash as an asset class in which client assets are invested from time to time. Un-invested cash assets are included in the Stephens Insured Bank Sweep Program (“Bank Sweep Program”), or for Employee Retirement Income Security Act (“ERISA”) and IRA accounts in a money market mutual fund. Professional Wealth Management In the Professional Wealth Management (“PWM”) program clients receive advice from seasoned professional managers, with individual attention to the client’s investment needs and objectives. Stephens or the Professional Wealth Management Financial Consultant (“PWM FC”) also provides brokerage and ADV Part 2A Appendix 1 7 March 31, 2025  other services to certain clients or engages in other functions and duties associated with Stephens’ business as advisor or as broker-dealer, to which they may devote as much time as necessary. In PWM, Stephens provides investment management services for client assets on a discretionary basis, utilizing strategies that include equity, fixed income, other investments, or a combination, in some cases that include alternative investments. The goal of the PWM program is to pursue an investment program to address the client’s investment objectives subject to market conditions. In balancing the potential return for a client’s portfolio against the risk exposure in the portfolio, PWM FCs consider the risk tolerances of the client, and discuss with the client their investment objectives. The client’s stated investment objectives and other information provided by the client, leads to an asset allocation strategy designed to seek to achieve returns based on and commensurate with the client’s risk tolerance and time horizon, without exposing the client’s portfolio to excessive risks. PWM FC’s are responsible for making day-to-day discretionary investment decisions subject to oversight and review by Supervisory Principals. Stephens Allocation Strategies The SAS program is an asset allocation program sponsored and administered through Stephens whereby the client is offered a strategy of purchasing a portfolio of “no load” or “load waived” mutual funds and Exchange Traded Funds (“ETFs), collectively known as (“Funds”), representing a broad spectrum of equities, fixed income, and alternative investment markets through Stephens. Fund Strategies Stephens, acting as the registered investment advisor, manages the selection of Funds representing each asset class included in the SAS asset allocation models in the program and establishes standard SAS model asset allocation portfolios for differing risk and time horizon parameters. Ongoing investment monitoring, fund replacement, periodic rebalancing, and investment performance measurement are provided by Stephens. Based on individual consultations with the clients and their investment objectives, a SAS asset allocation model recommendation is selected by the FC for the client’s account, intended to reflect the investment objectives, risk tolerance and investment time horizon communicated to the FC by the client. Following client’s approval of the recommended asset allocation, Stephens will initiate and Pershing will execute all transactions that are required to manage the client’s account in accordance with such asset allocation. Best execution is sought for all transactions. Stephens has investment discretion to change the Funds representing any asset class, to add or eliminate asset classes from the asset allocation model and to adjust the standard SAS asset allocation models, all consistent with the client’s investment objectives and other information as communicated to Stephens. Account Rebalancing/Model Changes Your account is automatically reviewed for rebalancing or needed model changes, and if needed, the rebalancing or changes are implemented. Rebalancing may involve adding or removing asset categories, which may require selling a fund and/or selecting one or more new funds for the account. In taxable accounts, rebalancing may cause a taxable event, and you should consult your tax advisor. Tactical Rebalancing Stephens reviews the account for rebalancing and, if necessary, rebalances it to the then current recommended allocation. Changes to Funds in the Program Stephens adds or removes Funds from the program from time to time at its discretion. Stephens reviews Funds, fund managers and fund companies on an ongoing basis to determine whether Funds should remain in the SAS program. Stephens may decide to terminate a Fund from the program if in Stephens judgment a change in the Fund company’s organization (such as personnel turnover) or a change in investment strategy process is so material that it is likely to affect the Fund’s performance or its ability to provide the ADV Part 2A Appendix 1 8 March 31, 2025  investment style for which it was originally selected. Mutual funds may also determine to discontinue offering their share class through the program or elect to change the share class offered in the program. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b-1 fees are received on client holdings, these will be rebated to the advisory client. Limited-Discretionary Wrap Programs Stephens provides wrap fee programs in which all or a portion of the client assets are managed by Stephens or designated third party investment managers (“Sub-Advisors”). Under these programs, the Sub-Advisor provides discretionary investment management services for the management of client assets. Each client enters into an Advisory Contract with Stephens. The Sub-Advisor in turn has a separate Sub-Advisory agreement with Pershing. The client pays an agreed fee monthly in advance to Stephens, based on the value of the eligible assets under management that covers the advisory fees of both Stephens and the Sub- Advisor. Positions allocated to cash as an asset class and un-invested cash assets are included in the Bank Sweep Program, or for ERISA or IRA accounts in a money market mutual fund. Stephens Managed Assets Program MAP is an asset allocation program sponsored by Stephens wherein Stephens manages the account or the client selects one or more participating Sub-Advisors to direct the investment of client’s assets. In this program, Stephens acts as the registered investment advisor establishing a separate account for the client. A separate account is a portfolio of individual securities managed for the client utilizing strategies that include equity, fixed income, other investments or a combination. Where the client chooses to engage one or more Sub-Advisors, the FC will assist in selecting the particular Sub-Advisors to manage or assist Stephens in managing the client’s assets based upon the client’s investment objective as described below. The Strategy A strategy is customized for the client by using sub-accounts (“Sub-Accounts”) which follow a strategy of Stephens or various Sub-Advisors selected by the client. Stephens will recommend Sub-Advisors to the client from the list of Sub-Advisors, which are included in Stephens’ list of available Sub-Advisors for the MAP program. The client’s stated investment objectives and other information provided by the client leads, in most situations, to an asset allocation strategy designed to seek to achieve returns based on and commensurate with the client’s risk tolerance and time horizon, without exposing the client’s portfolio to excessive risks. Sub-Advisors not currently available through Stephens may be added at Stephens’ sole discretion. In the MAP program, certain Sub-Advisors provide Pershing with their recommended Model Portfolios, and Stephens can deviate from the recommended models if it deems appropriate. In these instances, Stephens has discretion over the client’s assets in the Sub-Account rather than the Sub-Advisor (“Model Sub- Advisor”). Where the Sub-Advisors selected by the client manage client’s assets directly rather than through a model, the Sub-Advisor (“Non-Model Sub-Advisor”) has discretion over client’s account. (Note: the term “Sub-Advisor” without further qualification or description includes both Model and Non-Model Sub- Advisors.) Information about the client is communicated to Stephens and to the Non-Model Sub-Advisors on the initial opening of the advisory account and from time to time, thereafter. A Stephens New Account Agreement (“Agreement”) and Advisory Contract must be completed by each client and maintained by Stephens. The Agreement contains account name and address, investment objective, and specific financial information. Client information may be updated from time to time upon notification from the client of any material changes and noted within the client file. Each Sub-Advisor will be responsible for complying with all legal and regulatory requirements applicable to its activities as the manager of funds in Sub-Accounts they manage. If Stephens or Pershing removes a Sub-Advisor from the list of Sub-Advisors available through Pershing, ADV Part 2A Appendix 1 9 March 31, 2025  Stephens will recommend that the client transfer management of any assets previously managed by the removed manager to a new Sub-Advisor or Sub-Advisors selected by client and included on the list of Sub- Advisors available through Stephens. Stephens will review the investment activities of the Sub-Advisors in management of assets and provide regular reports on the status and performance of the Sub-Advisors. Pershing will execute all transactions on Stephens’ behalf in a client’s account following the instructions of the client and/or the designated Sub-Advisor(s), unless the investment is below the minimum amount of shares allowed to trade. Generally, Sub-Advisors in the MAP program either provide Pershing with their model portfolio or direct their trading to Pershing for execution. In both of these situations, Pershing executes these trades at no additional charge to the clients because execution charges are included in the wrap fee the client pays Stephens. However, to achieve best execution and for other reasons, Non-Model Sub-Advisors have the ability to trade away from Pershing. When Non-Model Sub-Advisors trade away from Pershing, clients will incur additional fees in the form of commissions per share or, for fixed income securities, additional fees per bond or on a per transaction basis which are embedded in the net price you receive. The number of Non-Model Sub-Advisors in the MAP program that direct trades to other broker-dealers can change as Non- Model Sub-Advisors are added or removed from the program. Certain equity/balanced strategies in the program have the ability to send trades for execution to broker- dealers other than Pershing, and trades executed away from Pershing will result in commission charges to Stephens’ clients in addition to the wrap fee the client paid to Stephens. These additional charges affect the net performance for the clients’ accounts. In the MAP program, certain Sub-Advisors can trade away from Pershing or Stephens in order to achieve best execution or other reasons. When the Sub-Advisor trades away this results in additional transaction charges being incurred by your account which are in addition to the advisory wrap fee you pay Stephens. The Sub-Advisors/strategies which traded away from Stephens or Pershing in the last two years are: Franklin Templeton All Cap Blend Balanced Portfolios (MDA0-Balanced) Franklin Templeton Appreciation Balanced Portfolios Franklin Templeton Appreciation Balanced Tax-Favored Portfolios Franklin Templeton Balanced Income Portfolios Legg Mason Balanced Income Taxable (70/30) Legg Mason Balanced Income with Municipals Legg Mason Balanced Income With Municipals (70/30) Franklin Templeton All Cap Growth Balanced Portfolios Franklin Templeton Custom MDA Portfolios Franklin Templeton Global All Cap Blend Balanced Portfolios (MDA8-Balanced) Franklin Templeton Large Cap Growth Balanced Portfolios Nuveen Preferred Securities The average cost of the execution charges during this period was $0.00 to $0.05 cents per share. Sub-Advisor Fees Where Sub-Advisors are selected, Stephens, on your behalf, pays a part of the fee Stephens receives from the client to the Sub-Advisor for services provided to the client. The portion of the asset-based fee paid by Stephens depends upon the asset class and the investment style. Stephens generally pays the Sub- Advisors between .25% and .55%. Stephens Unified Managed Account ADV Part 2A Appendix 1 10 March 31, 2025  The UMA program is a wrap fee program sponsored by Stephens that offers clients the ability to integrate investment products into a single advisory account. This program allows clients to construct a portfolio with allocations to various strategies (“Sleeves”), which consist of any of the following investment products (“Products”): (i) mutual funds; (ii) ETFs; and (iii) securities selected in model portfolios by one or more Sub- Advisors. Where the client chooses to engage one or more Sub-Advisors, the FC will assist in selecting the particular Sub-Advisors to manage or assist Stephens in managing the client’s assets based upon the client’s investment objective as described below. The Strategy The UMA program is based on asset allocation Sleeves. Based upon the client’s stated investment objectives and other information provided by client, an asset allocation strategy is developed to seek to achieve returns based on and commensurate with the client’s risk tolerance and time horizon, without exposing the client’s portfolio to excessive risks. The FC, with approval from the client, can select any asset allocation as long as at least two Sleeves are chosen. Stephens selects the Products that are available in the UMA program and determines which Sleeve will contain each product based upon its respective investment strategy. Products offered in the UMA program do not represent the full spectrum of products available through other programs offered by Stephens. Products available in the UMA program may be subject to certain investment minimums, as may be determined by Stephens and/or the relevant Sub-Advisor or Fund. Products not currently available in the UMA program may be added at Stephens’ sole discretion. In the UMA program, Stephens has investment discretion to change the Product selections within each asset allocation Sleeve. With the client’s written consent, Stephens will add or remove asset classes or, otherwise, adjust the asset allocation that was approved by the client as long as the assets remain in the UMA program. If Stephens removes a Product from the list of products available in the UMA program, Stephens will notify the FC of the change and provide 30 days’ notice to implement a change to another Product within that Sleeve or contact the client and discuss changes to the overall asset allocation. After the 30-day period, Stephens will select the replacement Product. Stephens will review the performance of the Products, and the FC can provide regular reports on the status and performance of the Products to the client. Pershing will execute all transactions on Stephens’ behalf in the client’s account following the instructions from the FC, the client or the designated Sub-Advisor(s), unless the investment is below the minimum amount of shares allowed to trade. Information about the client is communicated to Stephens and to a Non-Model fixed income Sub-Advisor on the initial opening of the advisory account and from time to time thereafter. An Agreement and Advisory Contract must be completed by each client and maintained by Stephens. The Agreement contains account name and address, investment objective and specific financial information. Client information may be updated from time to time upon notification from the client of any material changes and noted within the client file. Generally, Sub-Advisors in the UMA program either provide Pershing with their model portfolio or direct their trading to Pershing for execution. In both of these situations, Pershing executes these trades at no additional charge to the clients because execution charges are included in the wrap fee the client pays Stephens. However, to achieve best execution and for other reasons, Non-Model Sub-Advisors have the ability to trade away from Pershing. When Non-Model Sub-Advisors trade away from Pershing, clients will incur additional costs for fixed income securities. The additional fees are per bond or on a per transaction basis which are embedded in the net price you receive. The number of Non-Model Sub-Advisors in the UMA program that directs trades to other broker-dealers can change as Non-Model Sub-Advisors are added or removed from the program. Account Rebalancing Stephens will review UMA program accounts annually for drift based on their initial allocations to the various strategy Sleeves. Accounts with absolute variances of 3% or more from their Sleeve allocations will be ADV Part 2A Appendix 1 11 March 31, 2025  rebalanced. In taxable accounts, rebalancing may cause a taxable event, and you should consult your tax advisor. Sub-Advisor Fees Where Sub-Advisors are selected, Stephens, on your behalf, pays a part of the fee Stephens receives from the client to the Sub-Advisor for services provided to the client. The portion of the asset-based fee paid by Stephens depends upon the asset class and the investment style. Stephens generally pays the Sub- Advisors between .25% and .55%. Stephens IA Consulting From time to time Stephens is asked to furnish clients with investment advice through arrangements which involve consultations and recommendations but do not involve trading of securities. In these consulting arrangements a separate Advisory Contract is entered into specifying the scope of the services which will be provided and the fee to be charged. Consulting services may be provided with a fixed fee, an annual fixed fee paid quarterly or an annual fee paid quarterly based on a percentage of the assets subject to the consulting contract. Fees are negotiated in advance and are payable as negotiated and agreed to by the client and Stephens. Either party may terminate a consulting contract upon written notice. In the course of providing these services, Stephens may develop and present periodic reports regarding the client’s investments. Retirement Advisory Programs – Non Discretionary Stephens Retirement Solutions In the RSP program, clients receive advice from the FC with individual attention to the client’s retirement investment needs and objectives. FCs provide advice to clients utilizing strategies that include equity, fixed income, balanced, other investments, or a combination. This program is designed for clients with limited trading requirements. FCs in the RSP program do not have discretionary authority over client retirement assets, and all transactions in client assets are directed by the client or by the client’s designee. Investment Services Stephens shall periodically provide you with investment advice, which can include recommendations regarding investing in available assets in a manner consistent with your investment objectives; and pursuant to your consent, which shall be obtained prior to each transaction, in order to accept transaction in the RSP account. Stephens will not provide advice with respect to positions classified as unsupervised assets in the account. Fees You pay a single asset-based fee determined in accordance with asset tiers, charged monthly, that covers the services provided by Stephens. Advisory fees apply to standard accounts and include investment advice, securities execution fees, certain custodial services, associated account reports and investment portfolio reports. This is a wrap fee. The minimum annual fee is $150 and the maximum annual fee is $5,500 based on the eligible assets under management. The portion of the total fee that is typically paid to the FC is between 25% and 50%. Stephens Retirement Access The SRA program is now closed to new investors. In the SRA program, clients receive advice from the FC with individual attention to the client’s retirement investment needs and objectives. FCs provide advice to clients utilizing strategies that include equity, fixed income, balanced, other investments, or a combination. This program is designed for clients with minimal trading requirements. FCs in the SRA program do not have discretionary authority over client retirement assets, and all transactions in client assets are directed by client or client’s designee. ADV Part 2A Appendix 1 12 March 31, 2025  Investment Services Stephens shall periodically provide you with investment advice, which can include recommendations regarding investing in available assets in a manner consistent with your investment objectives; and pursuant to your consent, which shall be obtained prior to each transaction, in order to accept transaction in the SRA account. Stephens will not provide advice with respect to positions classified as unsupervised assets in the account. Fees You pay a single fee that amounts to $100 annually, charged in equal amounts monthly, that covers the services provided by Stephens. Advisory fees apply to standard accounts and include investment advice, securities execution fees, certain custodial services, associated account reports and investment portfolio reports. This is a wrap fee. The portion of the total fee that is typically paid to the FC is between 25% and 50%. Financial Planning Services Stephens offers comprehensive financial planning services to its clients in order to assist clients in identifying and striving to achieve long-term financial goals for themselves and their families. These services can include personalized financial planning and investment recommendations, and assistance with other financial matters, including trusts and estates and taxation issues. Stephens provides the client with these services based upon the information provided by the client and the results of the financial plan. The client is under no obligation to act upon the recommendations of Stephens. If the client does elect to act on any of the recommendations, the client is under no obligation to effect the transactions through Stephens. Comparing Costs Depending on the level of trading and types of securities purchased or sold in your account, you may be able to obtain transaction execution at a higher or lower cost by purchasing securities separately at Stephens than by paying a fee in these Programs. Additional Fees In these Programs, you will pay Stephens an asset-based fee for investment advisory and other services provide by Stephens or Pershing. These services include custody of securities and trade executions through Pershing on behalf of Stephens. The program fees do not cover: • • the costs of investment management fees and other expenses charged by Funds and UITs; “mark-ups”, “mark-downs”, and dealer spreads that Stephens receives when acting as principal in certain transactions where permitted by law; • brokerage commissions or other charges resulting in transactions not effected through Stephens with Pershing • account transfer fees; • processing fees; or • certain other costs or changes imposed by third parties As your introducing broker-dealer, Stephens can receive or pay compensation for directing order flow in equity securities. Pershing receives compensation for the direction of order flow in certain equity securities and listed options; the source and nature of the compensation, if any, received in connection with trades will be furnished upon your written request to your FC. Stephens Insured Bank Sweep Program The Stephens Insured Bank Sweep Program (“Bank Sweep Program”) is available to Stephens’ clients through Pershing, and Pershing has appointed IntraFi Network LLC (“IntraFi”) to provide certain services in connection with the Bank Sweep Program. In the Bank Sweep Program, each bank participating in the ADV Part 2A Appendix 1 13 March 31, 2025  program pays a return based on the amount of funds in your Deposit Account at the bank. The interest rate applicable to your Deposit Accounts is determined by the amount of interest participating banks are willing to pay on the aggregate balance of the deposits minus: (i) the fees paid to IntraFi, as administrator, (ii) the fees paid to Pershing for its services, and (iii) the fees paid to Stephens. Stephens retains and exercises the right to negotiate its own fee and may reduce or increase its fee. Because an increase in fees to Stephens reduces the effective amount of the interest rate that is ultimately paid to customers, Stephens has a conflict of interest with regard to the Bank Sweep Program. Stephens’ compensation, exclusive of the fees paid to Pershing and IntraFi for the Bank Sweep Program as applied to all clients will not exceed 6% per annum on the aggregate balances in the Deposit Accounts at the program banks. The total amount of the fee Stephens charges affects the amount of interest payable to clients on their Deposit Accounts since the higher Stephens’ fee is, the lower the amount of interest that is paid to Stephens’ clients. Stephens charges investment advisory fees as a percentage of client assets under management which includes cash assets in the Bank Sweep Program. This means that clients will pay Stephens’ investment advisory fee in addition to the fees charged in the Bank Sweep Program which are described above. More information on the current rates of return and fees is available at www.stephens.com/investment-disclosures/ which is incorporated herein. The interest rates on the Deposit Accounts will vary based upon the aggregate balance of all your “linked” Stephens accounts registered with the same tax ID number. This is referred to as your “Household Balance” and is described in more detail at www.stephens.com/investment-disclosures/. The rates and the Interest Rate Tiers may change from time to time. Further information on the Bank Sweep Program is available at www.stephens.com/investment-disclosures/stephens-insured-bank-sweep-program-rates/. These disclosures are incorporated herein. The interest rates paid on the Deposit Accounts at a Bank may be higher or lower than the interest rates available to depositors making deposits directly with the Bank or other depository institutions in comparable accounts and for investments in the money market mutual funds and other cash equivalent investments available through Stephens. You should compare the terms, interest rates, required minimum amounts, and other features of the Bank Sweep Program with other accounts and alternative investments. In deciding whether to participate in the Bank Sweep Program, clients should consider the return they are expected to receive versus the safety of the program. Banks participating in the Bank Sweep Program are not selected by Stephens, and each bank participating in the Bank Sweep Program is covered by FDIC deposit insurance up to the applicable FDIC limit. Banks in the program are expected to have acceptable credit but may not have “top tier” credit, and clients should evaluate credit quality and FDIC insurance coverage together with the return they are expected to receive. Funds in Advisory Programs Investing in Funds is more expensive than other investment options offered in your advisory account. In addition to our investment advisory fee, you pay the fees and expenses charged by the 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 of the Fund’s share price. These fees and expenses are an additional cost to you and are not included in the fee amount in your account statement. Each Fund expense ratio (the total amount of fees and expenses charged by the Fund) is disclosed in the prospectus. You do not pay a sales charge for purchases of mutual funds in your advisory account. However, some mutual funds charge, and do not waive, a redemption fee on certain transaction activity in accordance with its prospectus. In many instances, client account assets are invested in money market funds, mutual funds, other investment companies, privately offered investment funds and other collective vehicles (collectively, “Funds”), and these investments have their own fees and expenses which are borne directly or indirectly ADV Part 2A Appendix 1 14 March 31, 2025  by their shareholders. Where Stephens or its affiliates act as investment advisor, sponsor, administrator, distributor, selling agent, or in other capacities to such Funds, these Funds are deemed to be “Affiliated Funds.” Stephens or a Stephens affiliate receives the fees paid pro rata by all shareholders or partners of Affiliated Funds as described in the Fund’s prospectus. Client account assets can also be invested in Funds which are unaffiliated with Stephens or a Stephens’ affiliate (“Unaffiliated Funds”). For both Affiliated Funds and Unaffiliated Funds in which Stephens’ client assets are invested, Stephens receives shareholder servicing fees and 12b-1 fees from Funds on an ongoing basis as compensation for the administrative, distribution and shareholder services provided by Stephens. These services include such things as record maintenance, shareholder communications, transactional services, client tax information, reports filings and similar such services. These fees are paid under a plan adopted by the Funds pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended. If Stephens receives 12b-1 fees from a Fund with respect to a client’s mutual fund investment in the client’s account and the client is paying Stephens an advisory fee on such investment, the 12b-1 fees will be rebated to the client’s advisory account. However, in client brokerage accounts which have mutual fund holdings Stephens does retain the 12b-1 fees and shareholder servicing fees paid by the Funds on these mutual fund holdings Mutual funds are available to investors in a variety of different share classes all of which carry different expense ratios. Fund share classes that pay higher compensation carry higher expense ratios than share classes of the same mutual fund with lower expense ratios. Investing in a mutual fund share class with a higher expense ratio will negatively impact an investor’s return. Consistent with our fiduciary duty to clients, Stephens will take reasonable steps to ensure advisory clients are invested in share classes of mutual funds with the appropriate expense ratio for their advisory account. Not all share classes are available to advisory clients of Stephens, and it is possible that cheaper share classes of a fund may be available directly with the fund, not available on the Pershing platform or away from Stephens. Additionally, because of the large number of mutual funds which are offered in an ever changing variety of different share classes, it is possible that investors may not receive cheaper share classes which come available after their initial investment in a fund. UITs Sales Charge There are, characteristically, two components of the UIT sales charge: the transactional sales fee and the creation and development ("C&D") fee. The transactional sales fee does not apply to advisory accounts. The C&D fee is paid to the sponsor of the trust for creating and developing the trust, which includes determining the trust objectives, policies, composition and size, selecting service providers and information services as well as providing other similar administrative and ministerial functions. Your trust pays the C&D fee as a fixed dollar amount at the close of the initial offering period. The sponsor does not use the fee to pay distribution expenses or as compensation for sales efforts. Affiliated and Certain Funds Clients that invest in mutual funds advised by Hotchkis & Wiley Capital Management LLC (“H&W”) or advised/sub- advised by Stephens Investment Management Group LLC (“SIMG”) would bear a proportionate share of the fees and expenses of those funds including the management fees, sub-advisory fees or other fees paid to H&W or SIMG. These fees and expenses include commissions or fees, if any, paid to Stephens in connection with portfolio transactions. Please refer to each mutual fund’s prospectus for a full discussion of the fees and expenses of each mutual fund. An affiliate of Stephens has an ownership interest in H&W, and SIMG is under common control with Stephens. Custodial Services Stephens entered into a fully disclosed clearing arrangement with Pershing effective November 15, 2019 wherein Pershing provides certain recordkeeping and operational services to Stephens and to Stephens’ clients. The services provided by Pershing include execution and settlement of securities transactions, custody of Stephens’ client accounts and extensions of credit for any margin transactions. ADV Part 2A Appendix 1 15 March 31, 2025  Pershing normally provides custodial account services to Stephens’ clients. Custodial services provided by Pershing include custody of securities in your account, periodic statements, certain tax reporting and other similar services. Pershing is a subsidiary of the Bank of New York Mellon Corporation and is located at One Pershing Plaza, 4th Floor – Jersey City, NJ 07399. Pershing will send your account statements, which you should carefully review. In addition to the account statements Pershing sends you, we may send you a quarterly performance report which among other things, lists your account holdings and performance. You should compare our report to the account statements you receive from Pershing. In the event of any discrepancy between our report and any statement you receive from Pershing regarding the same investment, you should rely on the statement from Pershing. Your account will be subject to the terms and conditions described in the Advisory Contract, Agreement and any separate agreement or agreements executed in connection with the account. Stephens includes custodial fees for custody services and securities services provided by Pershing within the wrap fee charge. If a client’s account is under a wrap fee Program, commission charges are included as part of the Stephens advisory fee unless the client has selected a third party advisor who “trades away” from Pershing. Clients may engage an independent custodian. The fees of any custodian other than Pershing are not covered by the wrap fee and are the separate responsibility of the client. Clients may direct trading through another broker or other execution venue, and, in such a situation, the client will be responsible for all costs and commissions incurred in connection with such trading. Pershing Relationship Pershing is the clearing firm for our securities business. Due to this business relationship, Pershing shares with us a portion of the transaction costs and fees you pay to Pershing for certain transactions and services. The compensation we receive is an additional source of revenue to Stephens, and it defrays our costs associated with maintaining and servicing client accounts. Your advisory fee is not reduced or offset as a result of any revenue that Pershing shares with Stephens. The following is a brief description of some of the revenue and other items. • Pershing pays us on a quarterly basis an Active Account Credit in support of our ongoing investment in various businesses, marketing and technology initiatives relating to the services we offer. This Active Account Credit is based on the total number of Stephens client accounts held on the Pershing platform. • Pershing also pays us a Basis Point Credit each quarter which is computed based on the total value of Stephens client accounts held on the Pershing platform. • Pershing also provides consulting and other assistance to us from time to time. • Stephens receives revenues from Pershing on any investor free credit balances. These revenues are not received by Stephens for free credit balances in ERISA or IRA accounts. • Stephens determines the margin debit interest rate and receives any amounts paid by clients in excess of the Fed Funds Target Rate plus 85 basis points. • Stephens determines the interest rate charged to clients who obtain non-purpose loans within parameters set by Pershing. Stephens receives 100 bps of the interest paid on the loan from Pershing except in situations where Stephens has agreed to receive a lesser amount. • Pershing pays us a placement fee for each CD purchased through Pershing by a Stephens’ client. • Pershing pays us a portion of the revenues it receives for banking services provided to clients. For the period January 1, 2024 through December 31, 2024, Pershing paid Stephens the following revenues: Interest based on investor free credit balances of $1,900,734 • A short interest rebate of $1,714,766 • • Margin interest credit of $836,256 • Active account and basis point credits of $1,563,496 ADV Part 2A Appendix 1 16 March 31, 2025  • Non Purpose Loan interest of $617,507 • Silver Account (i.e. checking account) fee of $35,750 • Fee Income-Pershing-Legal/Transfer $7,600 • Pershing-Money Market Invesco ATRR $243,432 Where Stephens receives compensation from Pershing, this presents a conflict of interest because Stephens and your FC have a greater incentive to make available, recommend, or make investment decisions regarding investments and services that provide additional compensation over those investments and services that do not. The Clearing Agreement between Stephens and Pershing is for an initial term of 10 years effective November 15, 2019, and it provides for a substantial termination penalty in the event Stephens terminates the Clearing Agreement prior to the end of the initial term. At the outset of the Clearing Agreement, the termination penalty was $15 million, and it declines $2 million each year to $5 million in years 6 through the end of the Clearing Agreement. The termination penalty serves as a disincentive for Stephens to terminate the Clearing Agreement in the event Stephens or its clients have a negative experience with Pershing or if Stephens believes another firm offers superior service. This creates a conflict of interest in that it could influence Stephens’ decision to remain with Pershing even though it may be in the best interest of Stephens or its clients to terminate the Clearing Agreement. You should only use the cost basis information provided on your custodial account statements for tax reporting purposes. Pershing’s mailing address is: Pershing LLC; One Pershing Plaza; Jersey City, New Jersey 07399. For IRA and other retirement accounts, Pershing may charge termination fees pursuant to an adoption agreement you enter into with Pershing, which authorizes Pershing to act as the IRA custodian for Internal Revenue Service purposes. Pershing may resign at any time as the IRA custodian and then you have the right to appoint a successor IRA custodian (Successor). Where an unaffiliated third party acts as custodian of account assets, Stephens does not have discretion to select where cash reserves will be held. The client and/or custodian will make the selection. ERISA and IRA Fees Fees charged by Stephens to accounts of ERISA or Internal Revenue Code (“the Code”) covered plans will comply with the limitations made applicable under ERISA or the Code. Where Stephens or an FC provides non-discretionary investment advice such as recommending the rollover of a 401k to an IRA account at Stephens, recommending opening an IRA account with Stephens, or recommending the transfer of an IRA from another firm to Stephens, this presents a conflict of interest since compensation will be paid to Stephens and the FC in connection with these services. In addition, Stephens charges different levels of fees on different investment services. Stephens has adopted policies and procedures to mitigate these conflicts, and to address provisions of and prohibitions under ERISA and the Code with respect to potential conflicts of interest and self-dealing. ERISA Section 408((b)(2) Disclosures You may be, or may be acting on behalf of, a pension plan governed by the Employee Retirement Income Security Act of 1974, as amended (ERISA). ERISA section 408(b)(2) requires most parties that provide services to employee benefit plans to disclose certain information to a responsible plan fiduciary. Generally, the service provider must disclose the services that it provides to the plan and the compensation that it expects to receive in connection with the services. Stephens’ disclosures are available at the following web address: www.stephens.com/ERISA408b2 If you are the responsible plan fiduciary, please view the disclosures on this website. If you are not the responsible fiduciary, please forward this information to the responsible fiduciary of the plan. ADV Part 2A Appendix 1 17 March 31, 2025  Please review this website periodically for any required updates. Principal Transactions Pursuant to SEC Rule 206(3), Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing the capacity in which it is acting. As a practical matter, the above requirements impose delays on the time at which principal transactions can be affected for advisory accounts, and thereby can impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. Investment advisory clients are advised that they have the option to seek execution of transactions recommended by the FC through broker-dealers other than Stephens. However, on transactions executed through Stephens with Pershing, Stephens or Pershing will not charge a commission to the client, except when an underwriting issue in which Stephens participates is purchased for an account; in this case, the sales concession and underwriting fees are built into the offering price. Stephens will strive to obtain “best execution” of transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances. Transactions in securities in which Stephens acts as a principal will only be effected for clients subject to the client’s written consent to such transaction indicating the quantity and dollar amount of the securities being purchased or sold. If Stephens is acting as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a client. IPO Retail Client Allocations Although underwriting initial public offerings (“IPOs”) on behalf of corporate and other types of issuer clients is a regular part of Stephens’ investment banking business, the frequency, share price, number of shares available, and other characteristics of such offerings vary widely over time. For example, in some years Stephens may participate as an underwriter in no, or only a few, IPOs. Factors that limit IPO product availability to clients through Stephens include: • Market conditions that make raising capital through IPOs less favorable or unfavorable for issuers, such as periods of high market volatility or depressed share prices. • Alternative investment options for institutional and retail investors that impact overall demand for IPO investments. • Lack of or diminished investor interest in market sectors in which Stephens’ issuer clients operate. • The availability of capital through other sources such as the private equity marketplace or attractive debt financing alternatives. • Diminished financial strength and business prospects of particular issuer clients that make them poor candidates for IPOs. • Lack of specific business needs of particular issuer clients for capital infusions. In addition, in many instances Stephens will only be a small participant in an IPO underwriting syndicate that is led by another firm or firms and, consequently, will have little or no control or influence over whether, or to what extent, shares in the IPO are allocated to retail accounts and, instead, are directed to institutional clients. The combination of these factors makes it impractical, if not impossible, for Stephens to determine how much and what types of IPO product will be available for allocation to its retail client accounts over any extended time period. That, in turn, effectively precludes Stephens from utilizing any type of rotational allocation system designed to ensure that all of its retail client accounts are treated equitably. Instead of attempting to allocate shares equitably across all retail client accounts, Stephens bases its share allocation decisions on an account-by-account methodology taking into consideration multiple factors, ADV Part 2A Appendix 1 18 March 31, 2025  including the following: • The number of shares available in the IPO for allocation to Stephens’ retail clients. • The customary desire of Stephens’ issuer clients to avoid small retail allocations to numerous accounts, which would increase the cost and administrative burden of communicating and dealing with unnecessarily large numbers of investors. • Share allocation requests received by the Stephens syndicate department from the FCs who manage the firm’s retail client accounts. • The level of sophistication of the FC submitting those allocation requests in evaluating and dealing with IPO investments. • The stated interest of a particular retail client in participating in IPOs, in general, or in a particular IPO, including the number of shares requested. • The suitability of the investment for the client, particularly if it is speculative in nature, as is sometimes the case in IPOs. • Whether the requested IPO allocation would result in an overconcentration of the security in the client’s account, resulting in lack of appropriate diversification. • Whether the IPO investment would be consistent with the investment strategy and objectives agreed to by the client and the FC. • Any applicable tax considerations. • Whether the client has adequate liquidity in the account, or otherwise, to fund the IPO investment. • Whether the FC is able to contact the client on a timely basis and obtain any documentation necessary to participate in the offering. • Whether based on the client’s prior investment practices or discussions with the FC, it appears likely that the client intends to quickly resell the shares in order to obtain short term trading profits as opposed to holding them in order to gain long term appreciation, sometimes referred to as “flipping.” Given the complexity and sometimes subjective nature of this analysis, and the fact that the applicability of these considerations may vary with respect to a particular retail client at any given time, Stephens does not attempt to ensure that the allocation of IPO shares across all of its retail client accounts is equitable and does not analyze the fairness of its allocation decisions over time. In practice, some retail client accounts will have far greater access to IPO allocations than others. In fact, based on past experience, only a very small percentage of Stephens’ retail clients will participate in IPOs. Nevertheless, clients who are interested in participating in IPOs or a particular IPO are encouraged to advise their FC of such fact. IPO Related Conflicts of Interest Flipping. Stephens has a long-standing policy of discouraging its FCs from allocating IPO securities to retail client accounts that appear likely to quickly resell the securities in order to obtain short term trading profits as opposed to holding them in order to gain long term appreciation. Excessive short term trading in the secondary market following an IPO has the potential of causing market disruption and depressing the price of the issuer’s securities, both of which would operate to the disadvantage of Stephens’ issuer clients. Accordingly, Stephens reserves the right to withhold IPO allocations to retail client accounts that have a history of flipping their IPO securities positions or advise their FC of their intent to flip the IPO securities they wish to purchase in a pending IPO. This policy creates a conflict of interest because, while it favors Stephens’ IPO issuer clients and Stephens’ long term interests as an underwriter, it may not be in the best interest of a retail client seeking to realize short term trading profits on the client’s IPO positions. In addition, Stephens may penalize clients who flip their IPO securities by reducing or eliminating IPO allocations to them in the future. Favoring Larger Allocations. Stephens’ issuer clients generally prefer that the underwriting syndicate avoid small retail allocations to numerous accounts, which would increase the cost and administrative burden of communicating and dealing with unnecessarily large numbers of investors. Major items of expense in that regard include the printing and mailing of large numbers of investor communications such as proxy statements and annual reports. Further, Stephens, itself, incurs higher transaction and ADV Part 2A Appendix 1 19 March 31, 2025  administrative costs if smaller IPO allocations are spread over a larger number of accounts. This overall situation creates a conflict of interest with respect to Stephens’ handling of smaller accounts because larger allocations mean that they will have less opportunity to participate in IPOs and gain the IPO experience that would potentially qualify them for participation in more IPOs. This methodology also has the potential of increasing risk for IPO investors to the extent that larger allocations would be expected to result in more concentration with respect to these types of typically more speculative securities. Advisory vs. Brokerage Accounts. If a retail client has both an advisory and a brokerage account, it may be in the best interest of the client to purchase IPO securities in the brokerage account. The client would pay the same offering price for the securities irrespective of which type of account is selected for the purchase. However, in a brokerage account no additional charges (in the form of commissions) would be incurred until the time the securities are sold, while in an advisory account the client would incur assets under management fees that could exceed the amount of such commissions depending on the length of the holding period. The risk of this disadvantage occurring is increased by Stephens’ policy against flipping, which is designed to encourage longer holding periods. Offerings with Less Demand. Based on Stephens’ previously described allocation process, there is a potential that a retail account that does not frequently participate in IPOs may have a greater opportunity to participate in IPOs that prove to be in less demand, particularly if Stephens receives a relatively large allocation for placement with its retail clients. Although Stephens, and its FCs, have limited ability to predict client demand for an IPO in advance of the pricing and effectiveness of the offering, certain of the criteria utilized in allocating shares, such as previous IPO experience and favoring larger allocations, may result in more favorable allocations to larger, more experienced retail accounts in connection with high demand offerings. On the other hand, these factors would be expected to have less of an impact with respect to offerings where there is less demand from retail clients relative to the size of the retail allocation Stephens receives. It is likely, although certainly not guaranteed, that IPOs for which there is high demand relative to supply will perform better in the post-offering market-place for at least some period of time. Clients That Do Not Have Access. Stephens relies primarily on its FCs to determine whether, and to what extent, their retail advisory clients are interested in participating in IPOs. Many accounts are simply too small to participate in IPOs when concentration and suitability factors are taken into consideration. And, in practice, only a small percentage of Stephens FC’s regularly submit IPO allocation requests on behalf of their clients. In many instances, retail clients are participating in one or more of the Stephens Private Client Group’s advisory platforms providing for fee based, discretionary management by the FC, a firm investment committee or a third party money manager. The vast majority of FCs rely on these platforms to achieve appropriate asset allocation for their clients and typically do not offer their clients the opportunity to participate in IPOs. Finally, Stephens FCs, in their discretion, may elect to offer IPO allocations to some clients but not others, and such decisions are unlikely to be reviewed by Private Client Group supervisors or Compliance Department personnel. Given these circumstances, retail clients interested in participating in IPOs should advise their FC of such fact. In addition to existing programs, Stephens added new platforms for IRA and ERISA accounts. These platforms provide for low cost, level fee charges to clients, and Stephens is not allowed to accept any other compensation with respect to the handling of the account, including the compensation it would receive in connection with the sale of IPO securities. Accordingly, Stephens does not allow these types of accounts to participate in IPOs. Compensation to the Financial Consultant If you invest in one of the Programs described in this brochure, a portion of the fees payable to Stephens in connection with your account is allocated on an ongoing basis to your FC. The amount allocated to your FC in connection with accounts opened in one of these Programs may be more or less than other investment advisory programs, or brokerage and other services. The payout to the FC on these programs typically ranges from 20% to 50%. ADV Part 2A Appendix 1 20 March 31, 2025  Item 5: Account Requirements and Types of Clients Account Minimums Generally, an asset minimum is required for the establishment and maintenance of accounts in the Programs. However, exceptions may be made to this policy in the discretion of Stephens. The account minimums per program are:  SA $25,000  PWM $25,000  MAP $100,000  UMA $200,000  SAS $10,000  RSP $3,000  SRA No Minimum Stephens or the client can terminate the Advisory Contract at any time following advance written notice. Only those clients we deem in our discretion suitable will be accepted into advisory programs. Types of Clients Stephens’ clients include individuals, trusts, banking and thrift institutions, pension and profit sharing plans, plan participants, charitable organizations, corporations, other businesses, state and municipal entities, investment clubs and other entities. Item 6: Portfolio Manager Selection and Evaluation Selection and Review of Portfolio Managers and Funds for the Programs Stephens Advisor SA is a non-discretionary advisory program where the client retains authority to make investment decisions. Stephens does not review, select or recommend portfolio managers. However, the FC must be appropriately licensed and have an acceptable compliance record. Professional Wealth Management As a general rule, Stephens requires each PWM FC to have a college degree and extensive experience with securities brokers, investment advisors, asset managers, investment bankers, financial institutions, insurance companies, or equivalent institutions. Such standards may be waived in exceptional cases. The PWM FC must be appropriately licensed, have an acceptable compliance record, and be approved by their branch managers, PCG senior management and the Chief Operating Officer. All PWM FCs are employees of Stephens. Stephens Managed Assets Program In the MAP program, we offer a wide range of investment strategies provided by Stephens and Sub- Advisors that we have selected and approved. If Sub-Advisors have more than one strategy, we may include only some of those strategies in the program, and may assign different statuses to different strategies. Our MAP Investment Committee evaluates Sub-Advisors and strategies. Sub-Advisors and strategies may only participate in MAP if they are on the Stephens approved list. Our Investment Committee has developed a disciplined process for evaluating investment managers. Our research is focused on a review of both qualitative and quantitative factors, factors that are designed to deliver a wealth of detailed information about the investment products available through this advisory program. ADV Part 2A Appendix 1 21 March 31, 2025  The client will select investments or an investment strategy or strategies following discussion with Stephens’ FC about their investment objectives, the recommended allocation and potential Sub-Advisors with which to implement proposed strategies. When the client approves a proposed strategy, the client’s account may be established and assets placed with the agreed Sub-Advisor(s) to operate the plan. The replacement of Sub-Advisors in a client portfolio may be recommended under the following circumstances: • Change of client’s investment situation or goals; • Sub-Advisor philosophy changes; • Sub-Advisor exposes client’s account to investment style change; • Sub-Advisor firm undergoes ownership change or major personnel change; • Sub-Advisor performance lags peer group benchmarks; • Stephens, in consultation with client, determines to effect a change; or • Sub-Advisor holds an unnecessarily large cash position. Stephens Unified Managed Account Program In the UMA program, we offer a wide range of investment strategies provided by Stephens, Sub-Advisors, and Funds that we have selected and approved. If Sub-Advisors or Funds have more than one strategy, we may include only some of those strategies in the program, and may assign different statuses to different strategies. Our MAP and UMA Investment Committee evaluates Sub-Advisors and their strategies and Funds. Sub- Advisors and strategies and Funds may only participate in UMA if they are on the Stephens approved list. Our Investment Committee has developed a disciplined process for evaluating investment managers. Our research is focused on a review of both qualitative and quantitative factors, factors that are designed to deliver a wealth of detailed information about the investment products available through this advisory program. The client will select investments or an investment strategy or strategies following discussion with Stephens’ FC about their investment objectives, the recommended allocation and potential Sub-Advisors and/or Funds with which to implement proposed strategies. When the client approves a proposed strategy, the client’s account may be established and assets placed with the agreed Sub-Advisor(s) and Funds. Sub-Advisors and Funds in a client portfolio are considered for replacement under some the following circumstances: • Change of client’s investment situation or goals; • Sub-Advisor or Fund philosophy changes; • Sub-Advisor or Fund exposes client’s account to investment style change; • Sub-Advisor firm or Fund undergoes ownership change or major personnel change; • Sub-Advisor or Fund performance lags peer group benchmarks; • The FC or client determines to effect a change; or • Sub-Advisor or Fund holds an unnecessarily large cash position. Stephens Allocation Strategies In the SAS advisory program, we offer a range of models provided by Stephens with a range of mutual funds and ETF that Stephens has selected and approved. Our SAS Investment Committee evaluates the Funds. Our SAS Investment Committee has developed a disciplined process for evaluating the Funds. Our research is focused on a review of both qualitative and quantitative factors, factors that are designed to deliver a wealth of detailed information about the Funds available through this advisory program. The replacement of Funds in a client portfolio may happen under the following circumstances: ADV Part 2A Appendix 1 22 March 31, 2025  • Fund’s philosophy changes; • Fund exposes client’s account to investment style change; • Fund and/or firm undergoes ownership change or major personnel change; • Fund performance lags peer group benchmarks; • Fund holds an unnecessarily large cash position. Stephens Retirement Access and Stephens Retirement Solutions SRA and RSP are non-discretionary retirement advisory programs where the client retains authority to make investment decisions. Stephens does not review, select or recommend portfolio managers. However, the FC must be appropriately licensed and have an acceptable compliance record. Review of Portfolio and Performance Stephens utilizes a portfolio system licensed from a third party to calculate the performance of client accounts and to prepare portfolio performance reports for clients. To determine the value of securities in your account, we generally rely on third party quotation services. If a price is unavailable or believed to be unreliable, Pershing may determine the price in good faith and may use other sources such as the last recorded transaction. Additional Reviews Stephens Advisor, Professional Wealth Management, Stephens Retirement Solutions, Stephens Retirement Access Performance is evaluated using internal metrics as well as industry standards. Stephens may periodically review performance information to determine compliance with company standards. Performance information to be used for evaluation purposes will not always be calculated on a uniform and consistent basis. The Supervisory Principal periodically reviews performance information to determine compliance, as further discussed in Item 9. Your FC may use a wide variety of investments in your advisory accounts, including equity and debt securities, Funds and other securities or other pooled investment products. Subject to approval by Stephens you may also consider using margin for non-retirement accounts, short-term trading and option strategies. Stephens does not review, select or recommend portfolio managers for these programs. Stephens Managed Assets Program To calculate the Sub-Advisor performance, Stephens relies upon performance information provided from the Sub- Advisor included in the MAP program and third party providers. Stephens does not regularly audit the calculation of this performance information. The performance review includes a comparison of the performance of Sub-Advisors with the performance of selected market indices and peer group averages to evaluate Sub-Advisors or prospective Sub-Advisors over time. The MAP Investment Committee meets at least quarterly to compare the Sub-Advisors on performance to selected investment benchmarks and evaluate other criteria. If warning signs are observed, a Sub-Advisor may be subjected to a probationary review and comparative analysis. Warning signs typically are based upon factors such as style inconsistency, manager changes, performance issues, or changes in investment philosophy. Stephens also performs a quarterly review of the accounts’ average return for the quarter. Stephens compares the quarterly performance returns for individual accounts to the quarterly performance returns for their peer accounts in the same strategy. Stephens then reviews “outliers” that have significantly higher ADV Part 2A Appendix 1 23 March 31, 2025  or lower quarterly performance returns than the average peer account in the same strategy. Stephens Unified Managed Account To calculate the Sub-Advisor performance, Stephens relies upon performance information provided from the Sub- Advisor included in the UMA program and third party providers. Stephens does not regularly audit the calculation of this performance information. The Sub-Advisor and Fund performance review includes a comparison of the performance of the Sub- Advisor or Funds with the performance of selected market indices and peer group averages in evaluating Sub-Advisors and Funds over time. The UMA Investment Committee meets at least quarterly to compare the Funds on performance to selected investment benchmarks and evaluate other criteria relating to the operation of the Funds. If warning signs are observed, a Fund or Sub-Advisor may be subjected to a probationary review and comparative analysis. Warning signs typically are based upon factors such as style inconsistency, manager changes, performance issues or changes in investment philosophy. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b-1 fees are received on client holdings, these will be rebated to the advisory client. Stephens Allocation Strategies The Fund performance review includes a comparison of the performance of the Funds with the performance of selected market indices and peer group averages to assist in evaluating the performance of Funds over time. The SAS Investment Committee meets at least quarterly to compare the funds’ performance to selected investment benchmarks and evaluate other criteria relating to the operation of the funds. If warning signs are observed, a Fund may be subjected to a probationary review and comparative analysis. Warning signs typically are based upon factors such as style inconsistency, manager changes, performance issues or changes in investment philosophy. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b-1 fees are received on client holdings, these will be rebated to the advisory client. Conflicts of Interest Conflicts of Interest Ownership Pursuant to SEC Rule 206(3), Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing the capacity in which it is acting. As a practical matter, the above requirements may impose delays on the time at which principal transactions may be effected for advisory accounts, and thereby may impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. Transactions in which Stephens acts as a principal will only be effected for clients subject to the client’s written consent to such transaction indicating the quantity and price of the securities being purchased or sold. If Stephens is acting as a market-maker or otherwise as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a client. ADV Part 2A Appendix 1 24 March 31, 2025  American Beacon Stephens Funds® and Hotchkis & Wiley Funds (“Affiliated Funds”) are funds managed by affiliates of Stephens and/or advisors in which affiliates of Stephens have a substantial ownership interest. ERISA accounts and IRA accounts are generally prohibited from investing in these Funds. Other advisory accounts may invest in the Affiliated Funds in an appropriate amount if: (1) the manager and the client determine that the investment is suitable for the account, and (2) the client signs an Affiliate Funds Consent Letter (“Consent Letter”) prior to directing the purchase of the affiliated fund shares. Hotchkis and Wiley Limited (“HW-UK”), a wholly-owned subsidiary of H&W, is a private limited company incorporated in England and Wales. HW-UK is an appointed representative and tied agent of Arlington Group Asset Management Limited (AGAM) since March 1, 2016. AGAM is authorized by the Financial Conduct Authority to carry out regulated activities. The Chief Executive of HW-UK is also an appointed representative of AGAM and may carry on certain regulated activities in Europe. Portfolio Management by Advisors Owned or Partially Owned by Stephens Affiliated Mutual Funds Stephens may from time to time engage in transactions on behalf of clients with Hotchkis & Wiley Capital Management LLC (“H&W”) or with mutual funds advised by H&W. H&W is an investment adviser registered with the SEC in which entities under common control with Stephens hold an ownership interest. H&W provides investment advisory services to corporate, pension, public, endowment, foundation, mutual fund and other clients, and H&W also advises its own family of mutual funds. Stephens may also from time to time engage in transactions on behalf of clients with Stephens Investment Management Group LLC (“SIMG”) or with mutual funds advised by SIMG. SIMG is an investment adviser registered with the SEC in which affiliates of Stephens hold the entire ownership of voting securities. SIMG provides investment advisory services for separate account clients and for mutual funds known as the American Beacon Stephens Funds® or other funds which may be added from time to time. Additionally, SIMG serves as one of the investment advisors to the following multi-manager mutual funds using its SMID Select Growth Strategy or Small Cap Growth Strategy: • Vanguard Explorer™ Fund; and • Bridge Builder Small/Mid Cap Growth Fund; and • First Trust Multi-Manager Small Cap Opportunities ETF (MMSC) H&W advised mutual funds and SIMG advised mutual funds are offered through Stephens’ broker dealer services and/or investment advisory services as part of an investment program. Clients that invest in H&W advised mutual funds or in SIMG advised mutual funds would bear a proportionate share of the fees and expenses of those funds including the management fees or other fees paid to H&W or SIMG. These fees and expenses include commissions or fees, if any, paid to Stephens in connection with portfolio transactions. Please refer to each mutual fund’s prospectus for a full discussion of the fees and expenses of each mutual fund. Stephens Sponsored Wrap Fee Program Stephens sponsors the Stephens Small-Mid Cap Core (“SMID Core”) Growth Program which is a wrap fee program sub-advised by SIMG that follows its SMID Core Growth Model. FCs are not financially incentivized to place clients in the SMID Core Growth Program versus any other wrap program or platform available at Stephens. However, a portion of the SMID Core account fees, generally representing twenty to fifty percent (20%-50%) of SMID Core fees, will be paid to SIMG for its portfolio management services, pursuant to a sub-advisory agreement between Stephens and SIMG. SIMG and Stephens share common ownership, which benefits from the compensation generated to SIMG as the result of a client investing in the SMID Core Growth Program. Depending on the level of trading, the value of the account, and types of securities purchased or sold, clients may be able to obtain transaction execution at a higher or lower cost if purchased separately at Stephens or SIMG than through this wrap fee program. ADV Part 2A Appendix 1 25 March 31, 2025  Affiliated Investment Management Activities Certain investment strategies offered by SIMG have been selected for inclusion in the Private Client Group’s (“PCG”) Managed Assets Program (“MAP”). Sub-Advisors and strategies may only participate in MAP if they have been approved by the MAP Investment Committee. The MAP Investment Committee employs a process for evaluating investment managers that includes both qualitative and quantitative factors. SIMG strategies participating in MAP are subject to the same due diligence and evaluation processes as sub-advisors or strategies that have no affiliation with Stephens. FCs are not financially incentivized to favor selecting SIMG strategies over non-affiliated sub-advisors or strategies. However, selection of an SIMG strategy in MAP generates compensation to SIMG, which shares common ownership with Stephens. Other Affiliations Certain entities affiliated with Stephens or under common control with Stephens hold an ownership interest in Alex Brown Realty, LLC, a registered investment adviser. From time to time, Stephens offers to its clients securities sponsored by Alex Brown Realty, LLC. Stephens sometimes refers clients to Stephens Insurance, LLC, an affiliated insurance agency under common control with Stephens, for advice pertaining to products that are provided through Stephens Insurance, LLC, and FCs may be eligible, subject to regulatory and legal requirements, to receive referral fees for insurance business referred. For further information that pertains to related persons of Stephens, please refer to “Other Potential Conflicts of Interest”. Other Potential Conflicts of Interest Stephens is a diversified financial services company that directly or through affiliates provides a wide variety of investment banking, securities, insurance and other investment-related services to a broad array of clients. These relationships could give rise to potential conflicts of interest. Any of the following types of transactions could present a potential for a conflict of interest. • Client account assets can be invested in interests of money market funds, mutual funds, other investment companies, privately offered investment funds and other collective vehicles (collectively, “Fund Vehicles”) for which Stephens or its affiliates acts as investment advisor, sponsor, administrator, distributor, selling agent, or in other capacities (“Affiliated Funds”). In addition, client account assets can be invested in interests of Fund Vehicles for which Stephens or its affiliates do not act as investment advisor, sponsor, and administrator or in other capacities. Stephens or its affiliates receive fees for services provided to such Fund Vehicles, which often include (but are not limited to) fees payable under a plan adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (“12b-1 fees”) and fees paid to compensate Stephens for providing administrative services, distribution services, shareholder services, investment advisory services or other services to or for the benefit of such Fund Vehicles. Stephens Inc. as a dually-registered broker- dealer is paid the retail 12b-1 fees for brokerage mutual fund investments. Where 12b-1 fees are received in advisory accounts, these fees are rebated to the client’s advisory account. • From time to time, client account assets are invested in transactions that involve or constitute a purchase, sale or other dealings with securities or other instruments for which (i) Stephens, (ii) an affiliate or employee of Stephens, (iii) an entity in which Stephens or an affiliate has a direct or indirect interest, or (iv) another member of a syndicate or other intermediary (where an entity referred to in (i), (ii), or (iii), above is or was a member of the syndicate), has acted, now acts, or in the future may act as an underwriter, syndicate member, market maker, dealer, broker, principal, agent, research analyst or in any other similar capacity, whether the purchase, sale or dealing occurs during the life of the syndicate or after the close of the syndicate. Stephens has an incentive to favor the securities of issuers for which it provides such services over the securities of issuers for which Stephens does not provide such services. Your FC also receives more money if you buy these investments. • Although underwriting initial public offerings on behalf of corporate and other types of issuer clients is a regular part of Stephens’ investment banking business, the frequency, share price, number of ADV Part 2A Appendix 1 26 March 31, 2025  shares available, and other characteristics of such offerings vary widely over time. For example, in some years Stephens may not participate as an underwriter in any, or in only a few, IPOs. For factors that limit IPO product availability to clients through Stephens see the section titled4 “Services, Fees and Compensation/IPO Retail Client Allocations/IPO Related Conflicts of Interest” for more detail. • Stephens or any other broker-dealer that is or may become affiliated with Stephens (the “Affiliated Brokers”), is expected to act as broker or dealer to execute transactions on behalf of client’s account. Client will not be charged a separate fee for brokerage services provided to the account by Affiliated Brokers. • Stephens or its affiliates sometimes effect transactions for the client’s account with other accounts for which Stephens or an affiliate provides investment advisory services (“Cross Trades”). Such Cross Trades are intended to enable Stephens to purchase or sell a block of securities at a set price and possibly avoid an unfavorable price movement that may be created through entrance into the market with such purchase or sell order. Stephens receives compensation from other accounts involved in a Cross Trade. • Subject to applicable regulations, Stephens or its affiliates sometimes execute Agency Cross Transactions for the client’s account. Agency Cross Transactions are transactions where Stephens, or any affiliate of Stephens, acts as broker for both the client’s account and the other party to the transaction. In such transactions, Stephens, or any of Stephens’s affiliates acting as broker, receives commissions from the other party to such transaction, to the extent permitted by law, in addition to its customary investment management or advisory fee for the client’s account. • Clients of other divisions of Stephens or clients of other advisory representatives of Stephens or Stephens, its principals, employees, affiliates and their family members, sometimes hold, and sometimes engage in transactions in, securities purchased or sold for the client or about which Stephens gives or has given client advice. The client’s account may purchase as investments securities of companies with which Stephens or its affiliates maintain investment banking relationships or other relationships or securities of companies in which Stephens or its affiliates have an ownership or other investment interest. • Subject to applicable law, Stephens sometimes pays fees to, and/or shares revenues with, affiliates or non- affiliates in connection with referrals for investment advisory accounts. For additional information regarding referral fees, please see Item 9. • Stephens, or its affiliates, may provide more than one type of service to the client (or a related organization), including (but not limited to), investment management services, investment advisory services, financial advisory services, underwriting services, placement agency services, investment banking services, securities brokerage services, securities custodial services, insurance agency services, insurance brokerage services, administrative services or other services, or any combination of services, all on such terms as may be agreed between Stephens (or its affiliate) and the client (or its related organization). • Other divisions and other advisory representatives of Stephens perform investment advisory services for clients other than the client and such other divisions or other advisory representatives of Stephens give advice or take action with respect to other clients that is similar to or different from the advice given or action taken for the client’s account, in terms of securities, timing, nature of transactions and other factors. Stephens will, to the extent practicable, attempt in good faith to allocate investment opportunities among its clients, including the client, on a fair and equitable basis. However, other divisions and other advisory representatives of Stephens will not undertake to make any recommendation or communication to client with respect to any security which such other divisions or advisory representatives may purchase or sell (either as principal or for any other client’s account) or recommend to any other client, or in which such other divisions or advisory representatives, or their respective principals, employees, affiliates or their family members, may engage in transactions. • Both advisory and brokerage clients of Stephens have the ability to borrow money against the collateral value of their accounts with non-purpose loans arranged through Stephens with third party banks. Stephens receives a fee which is paid by the third party banks in an amount which varies but can be up to 1.35% of the monthly outstanding balance of the client’s loan. Part of the fee is passed along to the FC, and this can create a conflict of interest. Since Stephens has not compared rates available elsewhere, clients may be able to obtain lower interest rates on their loans through other banks. ADV Part 2A Appendix 1 27 March 31, 2025  • Stephens, Pershing and IntraFi receive fees and benefits for services provided in connection with the Bank Sweep Program. Stephens offers the Bank Sweep Program as a service and is not obligated to offer you this or any sweep product or to make available to you a sweep product that offers a rate of return that is equal to or greater than other comparable products or investments. Stephens has an economic incentive to make available to our clients sweep options that are more profitable to us than other sweep options. Each Bank will pay Stephens a fee equal to a percentage of the average daily deposit balance in your Deposit Accounts at the Bank. Because the Banks pay different amounts, the compensation paid to Stephens will vary from Bank to Bank. Because the interest rates paid to clients are subject to tiers based on the aggregate value of accounts within the client’s Household Balance, Stephens’ compensation rate is higher on client’s cash in lower interest rate tiers and lower on client’s cash balances in higher rate tiers. Stephens may reduce its fee and may vary the amount of the reductions between clients. The interest rate applicable to your Deposit Account is determined by the amount of interest participating banks are willing to pay on the aggregate balance of the deposits minus: (i) the fees paid to Intrafi Network LLC, as administrator, (ii) the fees paid to Pershing for its services, and (iii) the fees paid to Stephens. Stephens retains and exercise the right to negotiate its own fee and may reduce or increase its fee. Because an increase in fees to Stephens reduces the effective amount of the interest rate that is ultimately paid to customers, Stephens has a conflict of interest with regard to the Bank Sweep Program. The tier applicable to your Deposit Accounts is determined based on your Household Balance as of the first business day following the fifteenth (15th) of the month. Stephens charges advisory accounts an investment advisory fee based on a percentage of client assets. In computing your investment advisory fee, cash balances in the Bank Sweep Program are included in the assets of your account when calculating the investment advisory fee earned by Stephens for management of your account. Therefore, Stephens is paid both its fee from the Banks on the Bank Sweep Program balance in your account, and, in addition, Stephens earns an investment advisory fee for your total balances in your account, including your balance in the Bank Sweep Program. This creates a conflict of interest, as Stephens earns more from Bank Sweep Program balances in investment advisory accounts than it would if such balances were held outside of the Bank Sweep Program or outside of the investment advisory account entirely, creating an economic incentive for Stephens to retain advisory assets in cash in the Bank Sweep Program. Your FC does not receive a portion of the fee paid to Stephens by the Banks. • The Stephens Investment Banking department may introduce its clients, prospective clients, or affiliates thereof, to Stephens Financial Consultants. This introduction is done in Stephens’s capacity as a registered broker-dealer, and not as a registered investment advisor. If the introduction results in a new account relationship, then for a period of years a portion of the net revenue from such account is allocated to the Investment Banking department as a referral fee. Such revenue is considered, along with other factors, in the determination of compensation for the introducing investment banker(s). This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. Portfolio Management Description of Advisory Services Stephens’ investment advisory services seek to tailor an investment program for the financial goals and objectives of a particular client. When we are engaged as an investment advisor, the client typically pursues one or more of our investment strategies. Clients may impose investment restrictions on their accounts, such as restrictions on investing in particular securities or types of securities or restrictions on investing in particular industries. ADV Part 2A Appendix 1 28 March 31, 2025  Except with respect to the payment of the fees or service charges or for correction of errors, Stephens is not authorized to withdraw or transfer any money, securities, or property out of a client’s account, without authorization from the client. Client acknowledges and understands that brokerage or securities transaction execution services provided by any person or entity other than Stephens or Pershing are separate from and in addition to the wrap fee for the account. Additionally, regular service charges shall apply to client’s account for brokerage services other than securities execution services provided by Stephens. Stephens and its affiliates perform advisory and/or brokerage services including investment reporting for various clients, and Stephens gives advice or take actions for other clients that differ from the advice given or the timing or the nature of any action taken for your account. In addition, Stephens may, but is not obligated to, purchase or sell or recommend for purchase or sale any security which Stephens or any of its affiliates may purchase or sell for their own accounts or the account of any other client. Stephens and Pershing will not charge commissions on securities transactions that are executed through Stephens or Pershing for advisory accounts. The client’s account would be responsible to pay any commission charges imposed by any other brokerage firm on any securities transactions executed through any other brokerage firm, and such charges would be in addition to the wrap fee and any other applicable charges incurred by your account. By executing trades through Stephens with Pershing, the client’s account might forego benefits, such as participation in block trades or negotiated transactions that might be available through other brokerage firms. For ERISA and IRA accounts, when Stephens provides non-discretionary investment advice to the client regarding such an account, we are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we are compensated can create conflicts of interest, so we have established procedures which require us to act in the client’s best interest and not put our interest ahead of the client’s. Stephens Insured Bank Sweep Program Stephens makes available to clients whose accounts are custodied at Pershing the opportunity to participate in the Bank Sweep Program. In this program all of the uninvested cash in a client’s account is automatically deposited, or “swept” into FDIC insured, interest-bearing deposit accounts at one or more banks which participate in the Bank Sweep Program. None of the banks participating in the Bank Sweep Program are owned by or affiliated with Stephens. For more information about the Bank Sweep Program please review these important disclosures at www.stephens.com/investment-disclosures/ which are incorporated by reference into this Form ADV Part 2A. Stephens offers the Bank Sweep Program as a service and is not obligated to offer this or any sweep product or to make available to a sweep product that offers a rate of return that is equal to or greater than other comparable products or investments. The interest rates paid on Deposit Accounts at a bank may be higher or lower than the interest rates available to depositors making deposits directly with the bank or other depository institutions in comparable accounts and for investments in other cash equivalent investments through Stephens. The Bank Sweep Program is not available to ERISA plans with accounts at Stephens such as employee benefit plans, retirement plans, defined contribution plans, defined benefit plans, (collectively, “ERISA accounts”) or to traditional and rollover IRA accounts, Roth, SEP, SIMPLE and inherited individual retirement accounts (“IRAs”); Keogh plans; and Coverdell education savings accounts. The Bank Sweep Program for your account should not be viewed as a long-term investment option. If you desire, as part of an investment strategy or otherwise, to maintain a cash position in your account for other than a short period of time and/or are seeking the highest yields currently available in the market for your cash balances, please contact your FC to discuss investment options that are available outside of the Bank Sweep Program to help maximize your return potential ADV Part 2A Appendix 1 29 March 31, 2025  consistent with your investment objectives, liquidity needs and risk tolerance. Please note, however, that available cash accumulating in your account will not be automatically swept into any investment you purchase outside of the Bank Sweep Program. Nothing obligates you to participate in the Bank Sweep Program. You may receive a higher rate of return through products offered outside the Bank Sweep Program, including Money Market Funds offered through your account with Stephens and Pershing. Each Deposit Account constitutes a direct obligation of the Bank and is not directly or indirectly an obligation of Stephens or Pershing. Stephens and Pershing do not guarantee in any way the financial condition of the Banks or the accuracy of any publicly available financial information concerning such Banks. You are responsible for monitoring the total amount of deposits that you hold with any one Bank, directly or through an intermediary, in order for you to determine the amount of deposit insurance coverage available to you on your deposits. Stephens and Pershing are not responsible for any insured or uninsured portion of a Deposit Account. Restrictions In the PWM, MAP and UMA programs clients can impose reasonable restrictions on account investments. For example, the client may restrict Stephens or the sub-advisor (“Sub-Advisor”) from buying specific securities, a category of securities (e.g., tobacco companies) or mutual funds and Exchange Traded Funds (“ETF”) shares, collectively known as (“Funds”). If you restrict a category of securities, we will determine which specific securities fall within the restricted category. In doing so, we can rely on our clearing firm, Pershing. Any restrictions imposed by the client on individual securities have no effect on Fund holdings since Funds operate in accordance with the investment objectives and strategies described in their prospectuses. In the three programs, the portion of the account that would have been invested in any restricted security or category of securities will be invested in cash or cash equivalents. This will impact the performance of the account relative to an account that is fully invested in securities. Wrap Fee Programs In addition to other indications of individual ownership, including the right to withdraw, hypothecate, vote, or pledge securities held in the wrap fee client’s account, a wrap fee advisory client has the ability to place limitations and/or restrictions on the investments in their portfolio. Where restrictions are imposed, Stephens will not knowingly make any discretionary investments of the client’s portfolio assets in violation of these restrictions, but the investment performance of the client’s account will likely differ (positively or negatively) from other clients following a similar investment strategy, that is not subject to the same restrictions. The minimum account size for wrap fee programs vary from program to program, and a person considering a wrap fee program should review the ADV for details regarding the operation of the program, its risks, fees, and other charges. The entire wrap fee is paid to Stephens for its services relating to each wrap fee account. In determining the suitability of an investment strategy for a particular wrap fee program client, we rely on the information provided by the client regarding the objectives of the client for each account. This information comes from, among other sources, personal interviews with the client and written questionnaires completed by the client and other communications with the client or its representative regarding the client’s situation, investment objectives, risk tolerances and investment restrictions, if any. Our strategies are not appropriate for all investors, and investors should only invest a portion of their portfolio in these Programs. In certain Programs, we have the discretionary authority to determine the securities, and the amount of securities, to be bought and sold for our clients without obtaining specific client consent. The discretionary authority regarding investments may, however, be subject to certain restrictions and limitations placed by the client on transactions in certain types of securities or industries or to restrictions or limitations imposed by applicable regulations. Performance-Based Fees and Side-By-Side Management Stephens typically charges clients an investment advisory fee based on the value of the assets in the client’s ADV Part 2A Appendix 1 30 March 31, 2025  account. On occasion, Stephens enters into performance fee arrangements with appropriate clients as discussed below. Only certain clients qualify for performance fee arrangements which compensate Stephens based, in part, on the performance of the client’s account. All fees are negotiable and vary depending on the size of the investment, the nature of the services to be rendered by Stephens to the client, and other factors. Performance fees are typically invoiced annually. Stephens only enters into performance fee arrangements with certain clients which are eligible to enter into these arrangements as defined in Rule 205-3 under the Investment Advisers Act of 1940 and in accordance with the requirements set forth in applicable laws, rules and regulations, and these arrangements are negotiated with the client on an individualized basis. The performance fee arrangement could create an incentive for Stephens to seek to maximize the investment return by making investments that are subject to greater risk, or are more speculative, than would be the case if Stephens’ compensation were not based upon the investment return or could create an incentive for Stephens to seek to limit investment returns by pursuing investments with reduced risk. With a performance fee arrangement Stephens’ fee is, in part contingent upon the returns on the client’s assets, which is computed based upon unrealized and realized appreciation or depreciation of client’s assets. This gives Stephens an incentive to favor performance with investment opportunities and therefore creates a conflict for Stephens. Accounts participating in a performance fee arrangement may pay Stephens more compensation, or less compensation, when compared to standard fee rates. Performance fee arrangements are not available for all investment accounts and must be approved by Stephens on a case-by-case basis. Performance fee rates are negotiable. A client may negotiate a base fee rate, performance fee rates, an index to be used to calculate the performance fee, or the use of no index in calculating the performance fee. Any performance fee that Stephens charges is intended to comply with Rule 205-3 and other applicable requirements under the Investment Advisers Act of 1940 (the “Adviser’s Act”). Stephens has an incentive to favor accounts which it charges a performance fee over other types of client accounts by allocating more profitable investments to performance fee accounts or by devoting more resources toward the accounts’ management. Stephens seeks to mitigate the potential conflicts of interest which arise from managing accounts that bear a performance fee through its policies and procedures, including those related to investment allocation, and by complying with the provisions of Rule 205-3 as stated above. Stephens has discretion not to accept these arrangements. Methods of Analysis, Investment Strategies and Risk of Loss Stephens utilizes street and independent sources for our research, but it is not the sole basis of our investment decision making process. Other sources of information utilized by Stephens can include industry data obtained from subscription services, company filings, street research and models. Stephens utilizes these services for real-time news and pricing. Stephens also utilizes other independent research sources for quantitative reports that measure such things as price changes, growth rates, profitability, valuation, earnings surprises and earnings revisions. These quantitative reports are used to help identify new securities that meet our investment criteria and to monitor existing holdings. Under certain Programs, such as PWM, your FC may currently provide investment advisory services for your discretionary portfolio. Your FC has the flexibility to adapt strategies to a changing financial environment while keeping your goals and objectives in mind. Investing in securities involves risk of loss that clients should be prepared to bear. The material risks associated with our strategies are: Alternative Investments - Investing in alternative investments can be highly illiquid, is speculative and not suitable for all investors. Certain alternative investment products place substantial limits on liquidity and the redemption rights of investors, including only permitting withdrawals on a limited periodic basis and with a significant period of notice and may impose early withdrawal fees. Investing in alternative investments is intended for experienced and sophisticated investors only who are willing to bear the high economic risks of the investment. Investors should carefully review and consider potential risks before investing. Certain ADV Part 2A Appendix 1 31 March 31, 2025  of these risks include: loss of all or a substantial portion of the investment due to leveraging, short selling, or other speculative practices; lack of liquidity, in that there may be no secondary market for the fund and none expected to develop; volatility of returns; restrictions on transferring interests; potential lack of diversification and resulting higher risk due to concentration of trading authority when a single advisor is utilized; absence of information regarding valuations and pricing; complex tax structures and delays in tax reporting; less regulation and higher fees than mutual funds; and advisor risk. Alternative investment products typically have higher fees (including multiple layers of fees) compared to other types of investments. Individual funds will have specific risks related to their investment programs that will vary from fund to fund. Debt Obligations - Investing in debt (bond) obligations entails additional risks, including interest rate risk such that when interest rates rise, the prices of bonds and the value of bond funds shares can decrease and the investor can lose principal value. Equity Market Risk – Overall stock market risks affect the value of the investments in equity strategies. Factors such as U.S. economic growth and market conditions, interest rates, and political events affect the equity markets. Foreign Debt Obligations - Investing in foreign debt obligations entails additional risks, including those related to regulatory, market or economic developments, foreign taxation and less stringent investor protection and disclosure standards. Foreign Securities - Investing in foreign securities presents certain risks that are not present in domestic securities. For example, investments in foreign and emerging markets present special risks including currency fluctuation, the potential for diplomatic and political instability, regulatory and liquidity risks, foreign taxation and differences in auditing and other financial standards. In addition to the greater exposure to the risks of foreign investing, emerging markets present considerable additional risks, including potential instability of emerging market countries and the increased susceptibility of emerging market economies to financial, economic and market events. Money Market Risk - An investment in a Money Market Fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although the fund seeks to preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in the fund. Yields will vary. Yield quotations more closely reflect the current earnings of the fund than the total return. Management Risk - Our judgments about the attractiveness and potential appreciation of a particular asset class, mutual fund or individual security may be incorrect and there is no guarantee that individual securities will perform as anticipated. The price of an individual security can be more volatile than the market as a whole and our investment thesis on a particular stock may fail to produce the intended results. Options Risk- Options involve risk and are not suitable for all investors. Small Cap and Mid Cap Company Risk - Investing in small cap and mid cap issuers involves a significantly greater risk than investing in larger, more established companies. The daily trading volume for small cap and mid cap issuers can be much lower than for more widely held, established companies. There may be periods when it is difficult to invest in or liquidate portfolio investments for our various investment strategies. This is particularly the case when breaking news on a company occurs or when significant market forces and events occur. In addition, small and mid-cap companies are more vulnerable to economic, market and industry changes. Because smaller companies often have limited product lines, markets or financial resources, or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than larger capitalization companies. Investors should only invest a portion of their total portfolios in these securities, and investors should be prepared to lose their entire investments. Certain Risks Associated with Cybersecurity. ADV Part 2A Appendix 1 32 March 31, 2025  With the increased use of technologies to conduct business, investment advisors, including Stephens rely in part on digital and network technologies (collectively, “cyber networks”). These cyber networks are susceptible to operational, information security and related risks and can be at risk of cyber-attacks. Cyber- attacks could seek unauthorized access to cyber networks for the purpose of misappropriating sensitive information, corrupting data, or causing operational disruptions. Cyber-attacks can potentially be carried out against the issuers of securities you have invested in, against third party service providers, or against Stephens itself by persons using techniques that range from efforts to circumvent network security, overwhelm websites, and gather intelligence through the use of social media in order to obtain information necessary to gain access to cyber networks. Although cyber-attacks potentially could occur, Stephens and Pershing maintains an information technology security policy and technical and physical safeguards intended to protect the confidentiality of internal data. Bank Sweep Program If you have on deposit through the Bank Sweep Program an amount of cash that exceeds the number of Banks multiplied by $250,000, the balances in excess of this amount will not be insured by the FDIC. In the event of a failure of a bank participating in the Bank Sweep Program, there may be a time period during which you may not be able to access your cash. If you have cash at a bank outside the Bank Sweep Program, this may negatively impact the availability of FDIC insurance for the total amount of your funds held within and outside the Bank Sweep Program. You are responsible for monitoring the total amount of deposits that you hold with any one Bank, directly or through an intermediary, in order to determine the extent of FDIC insurance coverage available to you on your deposits, including the Deposit Accounts. Financial Consultants or Stephens Acting as Portfolio Manager Stephens Advisor In this program, FCs or supervised person of Stephens do not act with discretion. Professional Wealth Management In connection with the PWM program, the PWM FC has discretionary authority to manage the assets in the account and authorizes Stephens to make such trades of securities or other property in the exercise of its discretion which it or the PWM FC determines to be appropriate based upon the investment objectives of the client. Stephens Managed Assets Program In connection with the MAP program, Stephens or the Sub-Advisor has direct discretion to buy or sell securities for the client accounts. In an account managed according to a model provided by a Sub-Advisor, Pershing would have authority to make the trades required to follow the model portfolio provided by the Sub-Advisor. In incidences where Stephens is designated as the Sub-Advisor for the client’s account under the MAP program, Stephens shall have sole discretionary authority to buy or sell securities for the client accounts. Pershing shall execute trades pursuant to instructions of the investment Sub-Advisors of the account. Each client will designate Stephens or one or more investment Sub-Advisors participating in the MAP program to manage portions of the account. Each investment Sub-Advisor shall have discretionary authority, subject to the client’s instructions or investment guidelines, to buy, sell and trade securities in each account managed by such investment Sub-Advisor, including but not limited to authority to reinvest dividends and other income distributions on a similar basis. Each client may from time to time request a modification of the portfolio allocation, change the investment Sub-Advisors or withdraw assets from the MAP program, subject to applicable account size minimums established by Stephens and Sub-Advisors from time to time and subject to limitations adopted by Stephens and Sub-Advisors on the frequency of such changes. Non-Model Sub-Advisors on your account may receive duplicate periodic statements to assist in transaction, analysis, reporting and other account servicing responsibilities. ADV Part 2A Appendix 1 33 March 31, 2025  Information about the client is communicated to Stephens and to Non-Model Sub-Advisors on the initial opening of the advisory account and from time to time, thereafter. An Agreement and Advisory Contract must be completed by each client and maintained by Stephens. The Agreement contains account name and address, investment objectives and specific financial information. Client information may be updated from time to time upon notification from the client of any material changes and noted within the client file. Stephens Unified Managed Account Program In connection with the UMA program, Stephens and/or a Sub-Advisor has direct discretion to buy or sell securities for the client accounts. In an account managed according to a model provided by a Sub-Advisor, Pershing would have authority to make the trades required to follow the model portfolio provided by the Sub-Advisor. In incidences where Stephens is designated as the Sub-Advisor for the client’s account under the UMA program, Stephens shall have sole discretionary authority to buy or sell securities for the client accounts. Pershing shall execute trades pursuant to instructions of the investment Sub-Advisors of the account. Each client will designate Stephens or one or more investment Sub-Advisors participating in the UMA program to manage portions of the account. Each investment Sub-Advisor shall have discretionary authority, subject to the client’s instructions or investment guidelines, to buy, sell and trade securities in each account managed by such investment Sub-Advisor, including but not limited to authority to reinvest dividends and other income distributions on a similar basis. Each client may from time to time request a modification of the portfolio allocation “sleeves”, change the investment Sub-Advisors or withdraw assets from the UMA program, subject to applicable account size minimums established by Stephens and Sub- Advisors from time to time and subject to limitations adopted by Stephens and Sub-Advisors on the frequency of such changes. Non-model Sub-Advisors on your account may receive duplicate periodic statements to assist in transaction, analysis, reporting and other account servicing responsibilities. Information about the client is communicated to Stephens and to Non-Model Sub-Advisors on the initial opening of the advisory account and from time to time, thereafter. An Agreement and Advisory Contract must be completed by each client and maintained by Stephens. The Agreement contains account name and address, investment objectives and specific financial information. Client information may be updated from time to time upon notification from the client of any material changes and noted within the client file. Stephens Allocations Strategies In connection with the SAS program, Stephens has discretionary authority to buy or sell securities for the client account. Each client will designate Stephens to manage its SAS account. Stephens shall have discretionary authority, subject to the client’s instructions or investment guidelines, to buy, sell and trade fund securities for client’s SAS account, including but not limited to authority to reinvest dividends and other income distributions on a similar basis and to rebalance client portfolios on a periodic basis. Each client may from time to time request a modification of the asset allocation or withdraw assets from the SAS program, subject to applicable account size minimums established by Stephens from time to time and subject to limitations adopted by Stephens on the frequency of such changes. Stephens Retirement Access In this program, FC or supervised person of Stephens do not act with discretion. Stephens Retirement Solution In this program, FC or supervised person of Stephens do not act with discretion. Investment Advisory Proxy Policies For proxy voting directed by Stephens, it is Stephens’ policy to vote proxies on securities that are owned in an account and held in custody by Pershing for the account and to utilize investment advisory policies and procedures, which are reasonably designed to vote client securities in the best interests of the client and to address how potential conflicts of interest are handled. Stephens’ proxy voting policy is to vote in favor of actions recommended by the issuer’s Board of Directors, ADV Part 2A Appendix 1 34 March 31, 2025  unless the FC or Stephens disagrees with the proposed action and elects to vote the shares against the recommendation of the Board of Directors. If there is not a Board of Directors recommendation on a proposed action, then the FC or Stephens will determine whether to vote for, against or abstain. If the client chooses to custody their securities away from Pershing it will be the responsibility of the client to vote or to arrange for the voting of their proxies. Stephens Advisor, Stephens Retirement Access and Stephens Retirement Solutions Stephens will not take any action with respect to the voting of proxies solicited by or with respect to the issuers of securities in which assets of the client may be invested from time to time, except to provide proxy materials to client. Stephens will have no power, authority, responsibility or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in the client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. Professional Wealth Management It is Stephens’ policy to vote proxies on securities that are owned in a discretionary account and held in custody by Pershing as stated under the Investment Advisory Proxy Policies above. Stephens Managed Assets Program Proxy voting on securities for Non-Model Sub-Advisors is to be directed by the Sub-Advisor managing such investment. Proxy voting on securities for Model Sub-Advisors are generally directed by Stephens. Stephens Unified Managed Account Program Proxy voting on securities for Non-Model Sub-Advisors is to be directed by the Non-Model Sub-Advisor managing such investment. Proxy voting on securities for Model Sub-Advisors and Funds are generally directed by Stephens. Stephens Allocation Strategies It is Stephens’ policy to vote proxies on securities that are owned in a discretionary account and held in custody by Pershing as stated under Investment Advisory Proxy Policies above. Conflicts of Interest On an annual basis Stephens will disclose to affected clients any identified potential material conflicts of interest by providing a list of said conflicts electronically or by mail. Where Stephens has identified a specific potential material conflict of interest relating to one or more matters to be voted on by shareholders, Stephens: (1) will notify affected clients of the potential conflict of interest, (2) will disclose how the proxy will be voted absent a voting direction from the client, and (3) will give affected clients the opportunity to vote the proxy themselves. Stephens will maintain a record of the voting resolution of any conflict of interest. Corporate Actions and Other Matters From time to time there may also be a variety of corporate actions or other matters for which shareholder action is required or solicited and with respect to which Stephens may take action that it deems appropriate in its best judgment except to the extent otherwise required by agreement with the client. These actions include, for example and without limitation, responding to tender offers or exchange offers, bankruptcy proceedings and proposed class action settlements. However, Stephens will have no power, authority, responsibility or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at ADV Part 2A Appendix 1 35 March 31, 2025  any time in the client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. Investment Advisory Proxy Voting Procedures Stephens’ procedures to implement the Firm’s proxy voting policy are as follows: • Proxy materials are received on behalf of clients in Stephens’ Reorganization Department (“Reorg Department”). • A Proxy Voting Notice which includes a link to the proxy voting materials is sent by the Reorg Department via e-mail to the respective advisory area. This Proxy Voting Notice will be used to instruct the Reorg Department as to how to vote the shares. • • Stephens will vote the proxy through the Reorg Department in accordance with applicable voting guidelines, either by electronically voting or by mailing the proxy in a timely and appropriate manner. • Unless the responsible FC or Stephens loses confidence in management of the issuer or the client directs the vote, Stephens will vote the shares as recommended by the Board of Directors of the issuer; If there is not a Board of Directors recommendation on a proposed action, then the FC will determine whether to vote for, against or abstain. Proxy Information Stephens will make available information of the firm’s proxy voting policy and procedures including information regarding how Stephens voted proxies, if requested. In response to any request as to how the client’s proxies were voted, the Chief Compliance Officer or his designee would provide the information to the client. Item 7: Client Information Provided to FCs and Sub-Advisors Stephens’ advisory programs are available to individuals, banks, foundations, pension and profit sharing plans, trusts, IRAs, endowments, corporations, partnerships and other entities requiring investment advisory services. Stephens’ investment advisory services business is focused on high net worth individuals, foundations and businesses. We provide investment advice to individuals, trusts, to boards and retirement plans, to corporate pension and retirement plans, to various foundations and private entities. Our investments include equities, fixed income, Funds, alternative investments, and other types of securities Additionally, we advise wrap fee accounts in various programs sponsored by affiliated and unaffiliated investment advisors. The Sub-Advisor typically establishes a minimum account size for each strategy, and you should refer to the Sub-Advisor’s wrap fee brochure for a discussion of minimum account sizes and whether the minimum account size can be waived. Our Advisory Programs Information about the client is communicated to the FC on the initial opening of the advisory account. An Agreement is completed reflecting information provided by the advisory client, and maintained by Stephens. The Agreement contains account name and address, investment objectives and specific financial information. Advisory account information is updated upon notification from the advisory client of any material changes and noted within the client file. The FC assigned to advise the account has access to the client’s data maintained by Stephens. For the MAP and UMA program the same information will be sent to the Non-Model Sub-Advisor at the time the account is opened and upon request thereafter. Item 8: Client Contact with FCs ADV Part 2A Appendix 1 36 March 31, 2025  Client Meetings The FC assigned to the client’s account is the client’s primary point of contact with Stephens. The FC must offer to discuss or meet no less frequently than annually with advisory clients. Clients are encouraged to contact the FC at any time if they have questions or would like to have additional discussions or meetings. If you have experienced any changes regarding your financial situation, investment objectives or risk tolerance, please contact your FC to see if any adjustments are necessary to your investment strategy. Sub-Advisor Contact Although clients are not prohibited from directly contacting Sub-Advisors in the MAP or UMA program, clients are encouraged to use their FC as their primary contact. Item 9: Additional Information Disciplinary Information Stephens Inc. voluntarily participated in the Securities and Exchange Commission’s Share Class Selection Disclosure Initiative, and on March 11, 2019 the SEC entered a Cease and Desist Order against Stephens in which Stephens neither admitted nor denied the allegations of the SEC’s Order. The Order alleged that Stephens did not fully disclose conflicts of interest related to the selection of mutual fund share classes for its advisory clients, and that Stephens purchased, recommended or held mutual fund share classes for client accounts which paid Stephens 12b-1 fees when less expensive share classes of the same funds were available which did not pay Stephens these 12b-1 fees. The Order directed Stephens to Cease and Desist from committing or causing any violations and any future violations of Sections 206(2) and 207 of the Investment Advisers Act of 1940 and ordered that Stephens be censured and pay disgorgement and prejudgment interest to advisory clients who held these more expensive mutual funds share classes in their advisory accounts. (IA Release No. 40-5196) In its capacity as a broker-dealer, Stephens has been subject to legal or disciplinary events in the ordinary course of its business, such as regulatory sanctions relating to compliance with broker/dealer trade reporting requirements and other regulatory actions. Affiliations Stephens, from time to time, enters into arrangements with other broker-dealers, investment advisors or other persons whereby such parties refer clients seeking advisory services to Stephens. For additional information regarding Stephens’ affiliations, please see Item 6 Conflicts of Interest above. Code of Ethics Stephens has adopted an Investment Advisory Code of Ethics (“Code”), which defines the requirements and expectations for the business conduct of all of its Investment Advisory employees, including employees of Stephens. Furthermore, all Stephens’ employees are expected to adhere to Stephens’ Mission and Values Statement and Code of Professional Conduct. The fundamental position of Stephens is that all aspects of its business are to be conducted in an ethical and legal manner in accordance with federal law and the laws of all states where the investment advisory divisions do business. In accordance with that position general principles apply: • The interests of Stephens’ clients are our first consideration. Any personal securities transaction, which would be detrimental or potentially detrimental to any client account and any personal securities transaction, which is designed to profit by the market effect of any client account, must be avoided. • All personal securities transactions should be conducted in such a manner as to be consistent with ADV Part 2A Appendix 1 37 March 31, 2025  • • the Code and to avoid actual or potential conflicts of interest or abuse of a Stephens’ employee’s knowledge of client information or client transactions. Investment advisor personnel should not take inappropriate advantage of their positions. Information concerning the identity of security holdings and financial circumstances of clients is confidential. Independence in the investment decision-making process is paramount. Accordingly, there are certain standards of conduct, which Stephens investment advisory employees follow to reduce potential conflicts with the interests of our clients. Stephens will provide a copy of the Code to any client or prospective client upon request. Conflict of Interest with Personal Trading and Client Trades To minimize potential conflicts of interest, advisory personnel who determine or approve what recommendations will be made for client accounts will not participate in Stephens’ proprietary trading activities and will not know what trading strategies are employed for its proprietary accounts. It should be noted, however, that Stephens allows purchases to be made in the marketplace by its employees of securities owned by any client account, provided that such purchases are made in amounts consistent with the normal investment practice of the person involved. Such purchases must be made after the investment advisory accounts managed by such employee (or in the management of which such employee participates) has completed its transactions in such securities. Under certain circumstances, employee transactions may be permitted prior to full completion of investment advisory division’s transactions. Such exceptions require prior approval of the Chief Compliance Officer or his designee and will only be granted after considering factors such as the time element involved in filling the order, market considerations, etc. Stephens Personal Trading Stephens’ personnel may not participate in IPOs. All employees are required to maintain their personal accounts and accounts in which they have a beneficial interest at Stephens unless the account has been specifically exempt in writing from this requirement. Stephens’ employees are required to provide copies of all of their trade confirmations and brokerage account statements to Stephens’ Compliance Department in order to permit the monitoring of compliance with personal trading policies and restrictions. Additionally, FCs are required to report all personal securities transactions no less than quarterly. Stephens’ Investment Advisory Code of Ethics (“Code”) requires employees to report violations of the Code to Stephens Chief Compliance Officer. Review of Accounts Supervision & Reviews Primary responsibility for the supervision of advisory accounts lies with the applicable Stephens Branch Office Manager (“BOM”). BOMs conduct a periodic review of activity in selected advisory accounts, considering suitability of transactions and general performance. BOMs may also consider levels of activity, timing of transactions, transactions in restricted securities, profitability, concentration in one security and individual objectives and needs of the client based on information provided by the client. In addition to the monthly reviews, designated principals at Stephens’ home office make quarterly reviews of the investment performance and investment strategy of selected accounts. The reviewers may refer accounts to the Compliance Department for further analysis if necessary. Reviewers are not assigned accounts by any formula or numerical standard. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b-1 fees are received on client advisory holdings, these will be rebated to the advisory client. Oversight PCG Supervisory and Trading and Pershing oversee the daily operations of the advisory programs. The MAP Investment Committee, the UMA Investment Committee and the SAS Investment Committee ADV Part 2A Appendix 1 38 March 31, 2025  responsibilities are to review client accounts and coordinate with FCs regarding adherence to the client’s investment objective with regard to allocation and performance. These committees rely on internal reports in their overall review process. When Stephens executes transactions for you through Pershing’s order execution system, you will receive written or electronic confirmation of the transaction which provides information regarding the transaction. You may elect to receive these quarterly. You will also receive a written or electronic monthly account statement if you had activity in your account during the month which will detail the activity and the positions in the account. If you have not had any activity during the month and have positions in your account, you will receive a written or electronic quarterly account statement which details the positions in your account. You may waive the receipt of account statements or confirmations after each trade in favor of e-delivery via https://stephensaccess.netxinvestor.com/nxi/welcome . You may also receive mutual fund prospectuses, where appropriate. Client Referrals and Other Compensation Neither Stephens nor any of our employees receives any sales awards or other prizes from any non- affiliated outside parties for providing investment advice to our clients. Stephens may enter into referral arrangements with its affiliates or between divisions of the Firm. This includes referrals to Stephens of prospective clients seeking investment advisory services. If the referral results in a new account relationship, then a portion of the net revenue from such account is paid to such entity or division as a referral fee, and such entity or division may pay some portion of the fee to the referring person. This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. Such arrangements are conducted in accordance with the Marketing Rule, as applicable, and the Advisers Act generally. FCs are eligible to receive referral fees for referring eligible clients to the Stephens Investment Banking division. For eligible investment banking referrals, referring parties are eligible to receive compensation as a percentage of net income earned by Investment Banking. Therefore, FCs are incentivized to refer clients to the Investment Banking division. Any such compensation to the FC is at the discretion of the Firm. Financial Information Stephens does not require or solicit prepayment of more than $1200 in fees per client six months or more in advance and, thus, has not included a balance sheet of its most recent fiscal year. Stephens is not aware of any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to our clients. Who to Contact We are pleased to have an opportunity to serve as your FC. If you have any questions about the information contained in this brochure or about any aspect of the services we provide, please do not hesitate to call Stephens at (877-891-0095). Clients often receive this information by electronic delivery. Stephens ADV and additional brochures are available at The https://www.stephens.com/investment-disclosures. To access your FC's SEC Advisor Biography, go to www.stephens.com , use the search bar in the top right corner of the home page and search by your FC's name. SEC Advisor Biographies are also available in the "Our People" section and are there for your review. ADV Part 2A Appendix 1 39 March 31, 2025  Definitions and Professional Designation Qualifications Accredited Investment Fiduciary® (AIF®) The Accredited Investment Fiduciary (AIF®) Designation is a professional certification that demonstrates an advisor or other person serving as an investment fiduciary has met certain requirements to earn and maintain the credential. The purpose of the Accredited Investment Fiduciary (AIF®) Designation is to assure that those responsible for managing or advising on investor assets have a fundamental understanding of the principles of fiduciary duty, the standards of conduct for acting as a fiduciary, and a process for carrying out fiduciary responsibility. The AIF® training curriculum is offered in distance education or a blended learning option to suit each Candidate's needs. Fi360’s Prudent Investment Practices cover four Steps (domains), twenty-one Practices (tasks), and seventy-nine Criteria that an investment fiduciary is expected to be able to perform. After passing the exam, a Candidate wishing to file for the AIF® designation must submit the accreditation application and accreditation fee. Six Hours of annual continuing education is required, a minimum of four of which must be delivered by Fi360 or one of Fi360's approved CE providers. Accredited Wealth Management AdvisorSM (AWMA® ) Individuals who hold the AWMA® designation have completed a course of study encompassing wealth strategies, equity-based compensation plans, tax reduction alternatives, and asset protection alternatives. Additionally, individuals must pass an end-of-course examination that tests their ability to synthesize complex concepts and apply theoretical concepts to real-life situations. All designees have agreed to adhere to Standards of Professional Conduct and are subject to a disciplinary process. Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standards of Professional Conduct and complying with self-disclosure requirements. The Chartered Financial Analyst (CFA) The CFA designation is awarded to investment professionals who have successfully completed the requirements set forth by the CFA Institute. CFA Institute has a long-standing history of and commitment to establishing a broadly accepted ethical standard for calculating and presenting investment performance based on the principles of fair representation and full disclosure. The goals in developing and evolving the Global Investment Performance Standards (GIPS) are to establish them as the recognized standard for calculating and presenting investment performance around the world and for the GIPS standards to become a firm’s “passport” to market investment management services globally. The CFA Institute is an international non-profit organization whose stated mission is to promote and develop a high level of educational, ethical and professional standards in the investment industry. To be eligible for the CFA designation, candidates must pass 3 examinations that test the academic portion of the CFA program, possess a bachelor’s degree from an accredited educational institution or equivalent, and have 48 months of acceptable professional work experience. The CFA curriculum includes the following subject areas: Ethical and Professional Standards; Quantitative Methods (such as the time value of money, and statistical inference); Economics; Financial Reporting and Analysis; Corporate Finance; Analysis of Investments (such as stocks and bonds); and Portfolio Management and Analysis (asset allocation, portfolio risk, and performance measurement). Chartered Financial Consultant® (ChFC®) The ChFC® Program offers comprehensive education in the essentials of financial planning, including insurance, taxation, retirement, and estate planning. It also addresses advanced areas such as behavioral finance, non-traditional family structures, and small business planning. There are no prerequisite courses required before you can begin the ChFC® Program, but to use the designation, you are required to have three years of full-time, relevant business experience and a high ADV Part 2A Appendix 1 40 March 31, 2025  school diploma or the equivalent. To receive and maintain the ChFC® designation, you must agree to comply with The American College Code of Ethics and Procedures and participate in the annual Professional Recertification Program (PRP) to maintain the designation. CERTIFIED FINANCIAL PLANNER™ (CFP®) To earn the CFP® designation, an individual must complete a college-level course of study addressing the financial planning subject areas determined by the Certified Financial Planner Board of Standards, Inc. (“CFP Board”), pass a comprehensive two-day examination developed by the CFP Board and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university) and demonstrate three years of full-time work experience in financial planning or a related field. CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning. Once the CFP® has attained the CFP certification, they are require to complete 30 credit hours of continuing education accepted by CFP Board every two years, including 2 hours of CFP Board-approved ethics continuing education. Certified Investment Management Analyst (CIMA) The CIMA certification signifies that an individual has met initial and on-going experience, ethical, education, and examination requirements for investment management consulting, including advanced investment management theory and application. Prerequisites for the CIMA certification are three years of financial services experience and an acceptable regulatory history. To obtain the CIMA certification, candidates must pass an online Certification Examination. The Certification Examination is a five-hour examination and has 125 multiple-choice questions and 15 non-scored, pretest questions. Each examination item (question) is related to an area of work performed by an investment management consultant/advisor. The topics have been identified through a job analysis. All examination items are written in a four-option, multiple-choice format. CIMA designees are required to adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and Guidelines for Use of the Marks. CIMA designees must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through Investment Management Consultants Association (IMCA). Certified Pension Consultant (CPC) The Certified Pension Consultant (CPC) credential is conferred by ASPPA to benefits professionals working in plan administration, pension actuarial administration, insurance and financial planning. CPCs work alongside employers to formulate, implement, administer and maintain qualified retirement plans. The CPC is the capstone credential, or highest credential, currently conferred by ASPPA. To earn the CPC credential, you must successful complete various exams, verify a minimum of two years’ experience in the retirement plan industry, provide two letters of recommendation and apply for the ASPPA credentialed membership. All credentialed members must acquire 40 hours of continuing education (CE) credits (2 of which must be Ethics) in a two-year cycle and renew their ASPPA Membership annually to retain their credential(s). The Certified Portfolio Manager (CPM®) The Certified Portfolio Manager (CPM®) designation is a collaboration of the Academy of Certified Portfolio Managers and Columbia University. The academic component is designed to provide a deeper understanding of fundamental security analysis, asset allocation, and portfolio management concepts for financial services industry professionals managing discretionary portfolios. The curriculum encompasses eight core concepts: • Quantitative Methods • Financial Statement Analysis • Corporate Finance • Fixed Income Analysis ADV Part 2A Appendix 1 41 March 31, 2025  • Equity Analysis • Fiduciary Responsibility • Derivatives Qualifying for the CPM® designation The current criteria for applicant eligibility are any of the following (1) A certificate, diploma or academic degree providing evidence of a four-year undergraduate degree (2) 3 years of employment in the financial services industry and (3) Letter of recommendation on behalf of the applicant who is employed in the financial services industry, written by a supervisor, where the credential requirements are desired for the training and development of the applicant. At the end of each calendar year, ACPM members are required to submit the following; Record of 20 completed continuing education hours. ACPM maintains a self-auditing continuing education policy. Answers to a series of Professional Conduct questions. Annual membership dues. All three items are due by December 31st of that calendar year. Certified Public Accountant (CPA) CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally include minimum college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting), minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA), and successful passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of continuing professional education (CPE) activities on an ongoing basis. Additionally, all American Institute of Certified Public Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct. Chartered Retirement Planning Counselor SM (CRPC®) The CRPC® is conferred by the College for Financial Planning. Individuals who hold the CRPC® designation have completed a course of study encompassing pre-and post-retirement needs, asset management, estate planning and the entire retirement planning process using models and techniques from real client situations. Designees renew their designation every two years by completing 16 hours of continuing education, reaffirming adherence to the Standard of Professional Conduct and complying with self-disclosure requirements. Chartered Retirement Planning Specialist SM (CRPS®) The CRPS® is conferred by the College for Financial Planning. Individuals who hold the CRPS® designation have completed a course of study encompassing the specialization in creating, implementing and maintaining retirement plans for businesses. They must pass an exam demonstrating their expertise. Successful applicants earn the right to use the CRPS designation with their names for two years. Designees renew their designation every two years by completing 16 hours of continuing education, reaffirming adherence to the Standard of Professional Conduct and complying with self-disclosure requirements. Qualified Plan Financial Consultant (QPFC) QPFC is the professional credential for financial professionals who sell, advise, market or support qualified retirement plans. The QPFC program provides an understanding of general retirement planning concepts, terminology, distinctive features of qualified plans and the role of retirement plan professionals. QPFC is for professionals with two to three years of retirement plan experience. A candidate will be expected to demonstrate a general proficiency of plan administration, compliance, investment, fiduciary, and ethics issues. The QPFC credential is available as an alternative to the CPFA® credential. The coursework and exam are the same for both credentials. Candidates must complete the NAPA CPFA® exam, agree to abide by the ARA Code of Professional Conduct, and apply for the credential. In order to maintain the credential, designees must complete 10 CE hours per calendar year, starting the year following when the designation was earned. ADV Part 2A Appendix 1 42 March 31, 2025 

SEC File No: 801-15510 Uniform Application for Investment Advisor Registration Stephens Inc. 111 Center Street Little Rock, Arkansas 72201-4430 877-891-0095 Website: www.stephens.com Stephens Fixed Income Management Program March 31, 2025 This wrap fee program brochure provides information about the qualifications and business practices of Stephens Inc. If you have any questions about the contents of this brochure, please contact us at 877-891- 0095 or www.stephens.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. information about Stephens Inc. also is available on the SEC’s website at Additional www.adviserinfo.sec.gov. Stephens Inc. is a registered investment adviser with the United States Securities and Exchange Commission. Registration does not imply a certain level of skill or training. ADV Part 2A Appendix 1 March 31, 2025 1  Item 2 Material Changes This is an annual update to the Stephens Fixed Income Management Program wrap fee program brochure. This section identifies and discusses material changes since the last annual update dated March 28, 2024. For more details, please see the item in this brochure referred to in the summary below. Item 9 was updated to disclose: (i) payments employees of Stephens Inc. and its affiliates can receive for referring prospective clients seeking investment advisory services, and (ii) payments Financial Consultants and Investment Advisor Representatives are eligible to receive for making referrals to Stephens Inc.’s Investment Banking division. ADV Part 2A Appendix 1 March 31, 2025 2  Item 3 Table of Contents Uniform Application for Investment Advisor Registration ........................................................... 1 Item 2 Material Changes................................................................................................................... 2 Item 3 Table of Contents ................................................................................................................... 3 Item 4 Services, Fees and Compensation......................................................................................... 4 Stephens Fixed Income Management .............................................................................................. 4 Investment Management Agreement ........................................................................................................... 4 Management Fee Schedule ........................................................................................................................... 5 Account Review ............................................................................................................................................. 6 Confirmations, Account Statements and Performance Reviews ............................................................... 6 Other Types of Fees and Expenses Clients May Pay .................................................................................. 6 Item 5 Account Requirements and Types of Clients .................................................................... 10 Conditions for Management ....................................................................................................................... 10 Types of Clients............................................................................................................................................ 10 Item 6 Portfolio Manager Selection and Evaluation .................................................................... 10 Education and Business Standards ............................................................................................................ 11 Performance Calculations ........................................................................................................................... 11 Advisory Services......................................................................................................................................... 11 Portfolio Managers ...................................................................................................................................... 11 Conflicts of Interest ..................................................................................................................................... 11 Portfolio Management Description of Advisory Services ........................................................................ 17 Item 7 Client Information Provided to Portfolio Managers ........................................................ 21 Item 8 Client Contact with Portfolio Managers ........................................................................... 22 Client Meetings ............................................................................................................................................ 22 Item 9 Additional Information ....................................................................................................... 22 Disciplinary Information ............................................................................................................................ 22 Affiliations .................................................................................................................................................... 22 Investment Advisory Code of Ethics .......................................................................................................... 22 Supervision and Review of Accounts ......................................................................................................... 23 Client Referrals and Other Compensation ................................................................................................ 23 Financial Information ................................................................................................................................. 24 Who to Contact ............................................................................................................................................ 24 Definitions and Professional Designation Qualifications ............................................................. 25 ADV Part 2A Appendix 1 March 31, 2025 3  Item 4 Services, Fees and Compensation Stephens Inc. ("Stephens") is an Arkansas corporation which registered with the Securities and Exchange Commission (“SEC”) as a broker dealer in September 1946. Stephens registered as an investment advisor with the SEC on September 19, 1980 and began providing investment advisory services. Stephens is a full service broker/dealer and investment bank. In addition to being registered with the SEC, Stephens is a member of the Financial Industry Regulatory Authority (“FINRA”), the New York Stock Exchange, Inc. (“NYSE”), the NYSE American LLC (“NYSE-AMEX”), the Municipal Securities Rulemaking Board (“MSRB”), the Investors’ Exchange LLC (“IEX”) and the Securities Investor Protection Corporation (“SIPC”). Stephens derives greater revenues from its broker/dealer and investment banking activities than it derives from its investment advisor activities. Stephens Fixed Income Management (“SFIM”) is a division of Stephens. Affiliates of Stephens are also separately engaged in financial services businesses, including merchant banking, insurance and investment advisory businesses. Stephens Fixed Income Management Stephens Fixed Income Management (“SFIM”) manages client assets on a discretionary basis, under the Stephens Fixed Income Management Program. All accounts are advised and managed by the Fixed Income Management Committee. The goal of SFIM is to seek to earn a high return on income investments for the client consistent with the client’s investment objectives subject to market conditions. SFIM seeks to fully invest balances at all times. The portfolio objective will be to invest in fixed income securities and money market funds, which invest in fixed income securities. Investment Management Agreement Entering into an advisory relationship with SFIM involves the execution of an Investment Management Agreement (“Advisory Agreement”) and a general account agreement. The term of the Advisory Agreement between the client and SFIM is generally for a period of one year beginning on the effective date of the agreement and is automatically renewed for successive additional one-year terms without further action by the parties. At the time of entering into the Advisory Agreement, the client has a right to terminate the agreement without penalty within five (5) business days after the entering into the agreement and receive a full refund of any investment advisory fees paid to Stephens. At any time, the agreement may be terminated without penalty by either the client or SFIM, upon fifteen (15) days’ notice given in writing to the other party. Upon termination of the agreement and payment of all sums which may be owed under the agreement, SFIM shall make such disposition of the managed securities or other property of the client held by it as may be directed by the client. The client will agree to pay SFIM the reasonable costs and expenses incurred for such disposition and collection, including attorney fees, for any unpaid balances under the agreement. From time to time, but only in special circumstances, the fees may be negotiable or otherwise varied. These fee arrangements could include flat fee, commission and/or performance compensation. Fees will be payable on a schedule as negotiated by the parties. On June 5, 2019, the SEC issued its interpretation of the Standard of Conduct for Investment Advisers and rescinded certain previously issued no action letters. As a result of these changes, Stephens will not seek to enforce any provision of an investment advisory agreement with a retail investor which discharges Stephens or its agents from liability to the retail investor client. ADV Part 2A Appendix 1 March 31, 2025 4  Management Fee Schedule Clients pay a wrap fee for Stephens’ services. SFIM calculates its fee based on a negotiated annual fee that is quoted in basis points. The portion of the total fee that may be paid to the portfolio manager is a variable rate not to exceed 42%. SFIM fees apply to standard accounts and include management, brokerage services* and investment management reports. SFIM fees are governed by the terms of the Advisory Agreement. In the event this agreement is terminated between quarter-ends, such fees shall be prorated as of the date of termination. The fee is deducted from the account by SFIM quarterly unless otherwise agreed in writing. SFIM clients will receive a Fee Statement shortly after the deduction of the fee. The fee for the period from the opening of the account (“effective date”) to the end of the calendar quarter shall be obtained by computing the weighted average of the daily market value of cash and securities in the portfolio during such period and multiplying the resultant weighted average market value by one-fourth of the applicable annual fee as indicated above, pro-rated for the percentage of the original calendar quarter during which the portfolio is under management. The fee for any subsequent three-month period shall be the amount obtained by computing the weighted average of the daily market value of cash and securities in the portfolio during such period and multiplying the resultant weighted average market value by one-fourth of the applicable annual fee as indicated above. * Investment advisory clients have the option to seek execution of transactions recommended by SFIM through broker-dealers other than Stephens. However, on transactions executed through Stephens, Stephens will not charge a commission to the client except when securities of an underwritten issue in which Stephens is in the syndicate are purchased for the account, in which case the sales and underwriting fees are built into the offering price. Collection of Fees Stephens, through Pershing, is authorized to deduct from your account each quarter the amount of the total quarterly wrap fee as described in the Advisory Agreement, and the other fees, if any, applicable to your account for such calendar quarter. Stephens will issue quarterly reports to you reflecting the transactions in your account and the performance of the investments. Is a Wrap Fee Arrangement for you? The SFIM program may cost the client more or less than purchasing such services separately depending upon such factors as trading activity, account size and investment adviser minimums for non-wrap accounts. We encourage you to carefully consider your options in establishing or maintaining an advisory fee-based account. As a general matter, a fee-based advisory account approach may be considered appropriate for customers who rely on investment advice or investment management services or who engage in moderate to high levels of trading activity. A fee-based approach can be more economical for customers who engage in active trading, since the price per trade is reduced as the number of trades increases under a fee-based approach. However, fee-based advisory account arrangements may not be appropriate for customers who rely primarily on their own independent resources and judgments for making their investment selections and decisions and do not wish to purchase advisory services. Customers who engage in a lower level of trading activity might prefer a traditional brokerage account with a commission payable on each transaction, particularly if the customer typically does not utilize advisory services for trading decisions, as transaction cost savings might be realized in the context of a traditional pay-per-trade commission structure. Typically, a portion of any revenue that the firm realizes in connection with an advisory account will be included in the calculation of the compensation to be paid by the firm to the investment advisory ADV Part 2A Appendix 1 March 31, 2025 5  representative (“IAR”); and, therefore, the IAR will experience conflicts of interest similar to those experienced by the firm. Account Review The SFIM IAR assigned to a client’s account will be the primary contact for the client at Stephens. SFIM IARs must offer to discuss or meet with clients periodically to discuss their investment portfolios and investment goals, not less frequently than annually. Clients are encouraged to contact their SFIM IAR at any time if the client would like to have additional discussions or meetings. If you have experienced any changes regarding your finances, investment objectives or risk tolerance, please contact your IAR to see if any adjustments are necessary to your investment strategy. Confirmations, Account Statements and Performance Reviews In most cases, Pershing is the custodian of your account and provides you with written or electronic confirmation of securities transactions and account statements at least quarterly. You will also receive a monthly account statement if you have had qualifying activity in your account during the month which will detail the activity and the positions in your account. If you have not had any qualifying activity during the month and you have positions in your account, you will receive a quarterly account statement which details the positions in your account. You may waive the receipt of account statements or confirmations after each trade in favor of e- delivery via stephensaccess.netxinvestor.com/nxi/login. You may also receive mutual fund prospectuses, where appropriate. We will provide you periodic reviews of your account. These show how the account investments have performed on an absolute basis. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b- 1 fees are received on client holdings these will be rebated to the advisory client. Other Types of Fees and Expenses Clients May Pay The wrap fee covers securities execution services provided by Stephens and Pershing LLC (“Pershing”) as custodian for the account. Clients may engage an independent custodian. The fees of any custodian other than Pershing are not covered by the wrap fee and are the separate responsibility of the client. Clients may direct trading through another broker or other execution venue, and, in such a situation, the client will be responsible for all costs and commissions incurred in connection with such directed trading. Fees for other services, such as administrative or transfer fees will be charged at Stephens’ standard rates in addition to the wrap fee. If an unaffiliated third party acts as custodian of account assets, typically the custodian and the client, and not Stephens, would determine where cash reserves will be held. Stephens Insured Bank Sweep Program The Stephens Insured Bank Sweep Program (“Bank Sweep Program”) is available to Stephens’ clients through Pershing, and Pershing has appointed IntraFi Network LLC (“IntraFi”) to provide certain services in connection with the Bank Sweep Program. In the Bank Sweep Program, each bank participating in the program pays a return based on the amount of funds in your Deposit Account at the bank. The interest rate applicable to your Deposit Accounts is determined by the amount of interest participating banks are willing to pay on the aggregate balance of the deposits minus: (i) the fees paid to IntraFi, as administrator, (ii) the fees paid to Pershing for its services, and (iii) the fees paid to Stephens. ADV Part 2A Appendix 1 March 31, 2025 6  Stephens retains and exercises the right to negotiate its own fee and may reduce or increase its fee. Because an increase in fees to Stephens reduces the effective amount of the interest rate that is ultimately paid to customers, Stephens has a conflict of interest with regard to the Bank Sweep Program. Stephens’ compensation exclusive of the fees paid to Pershing and IntraFi for the Bank Sweep Program as applied to all clients will not exceed 6% per annum on the aggregate balances in the Deposit Accounts at the program banks. The total amount of the fee Stephens charges affects the amount of interest payable to clients on their Deposit Accounts since the higher Stephens’ fee is, the lower the amount of interest that is paid to Stephens’ clients. Stephens charges investment advisory fees as a percentage of client assets under management which includes cash assets in the Bank Sweep Program. This means that clients will pay Stephens’ investment advisory fee in addition to the fees charged in the Bank Sweep Program which are described above. More information on the current rates of return and fees is available at www.stephens.com/investment-disclosures/ which is incorporated herein. The interest rates on the Deposit Accounts will vary based upon the value of the assets you maintain in your Stephens’ household accounts, including amounts on deposit in your Deposit Accounts (“Interest Rate Tiers”). The rates and the Interest Rate Tiers may change from time to time. Further information on the Bank Sweep Program is available at www.stephens.com/investment-disclosures/stephens- insured-bank-sweep-program-rates/. These disclosures are incorporated herein. The interest rates paid on the Deposit Accounts at a Bank may be higher or lower than the interest rates available to depositors making deposits directly with the Bank or other depository institutions in comparable accounts and for investments in the money market mutual funds and other cash equivalent investments available through Stephens. You should compare the terms, interest rates, required minimum amounts, and other features of the Bank Sweep Program with other accounts and alternative investments. In deciding whether to participate in the Bank Sweep Program, clients should consider the return they are expected to receive versus the safety of the program. Banks participating in the Bank Sweep Program are not selected by Stephens, and each bank participating in the Bank Sweep Program is covered by FDIC deposit insurance up to the applicable FDIC limit. Banks in the program are expected to have acceptable credit but may not have “top tier” credit, and clients should evaluate credit quality and FDIC insurance coverage together with the return they are expected to receive. Custodial Services Pershing normally provides custodial account services to Stephens’ clients. Custodial services provided by Pershing include custody of securities in your account, periodic statements, certain tax reporting and other similar services. Pershing is a subsidiary of the Bank of New York Mellon Corporation and is located at One Pershing Plaza, 4th Floor – Jersey City, NJ 07399. Pershing will send your account statements, which you should carefully review. In addition to the account statements Pershing sends you, we may send you a quarterly performance report which among other things, lists your account holdings and performance. You should compare our report to the account statements you receive from Pershing. In the event of any discrepancy between our report and any statement you receive from Pershing regarding the same investment, you should rely on the statement from Pershing. Your account will be subject to the terms and conditions described in the Advisory Agreement and any separate agreement or agreements executed in connection with the account. ADV Part 2A Appendix 1 March 31, 2025 7  Stephens includes custodial fees for custody services and securities services provided by Pershing within the wrap fee charge. If a client’s account is under a wrap fee program, commission charges are included as part of the Stephens advisory fee unless the client has selected a third party adviser who “trades away” from Pershing. Clients may engage an independent custodian. The fees of any custodian other than Pershing are not covered by the wrap fee and are the separate responsibility of the client. Clients may direct trading through another broker or other execution venue, and, in such a situation, the client will be responsible for all costs and commissions incurred in connection with such trading. Pershing Relationship Pershing is the clearing firm for our securities business. Due to this business relationship, Pershing shares with us a portion of the transaction costs and fees you pay to Pershing for certain transactions and services. The compensation we receive is an additional source of revenue to Stephens, and it defrays our costs associated with maintaining and servicing client accounts. Your advisory fee is not reduced or offset as a result of any revenue that Pershing shares with Stephens. The following is a brief description of such revenue and other items. • Pershing pays us on a quarterly basis an Active Account Credit in support of our ongoing investment in various businesses, marketing and technology initiatives relating to the services we offer. This Active Account Credit is based on the total number of Stephens client accounts held on the Pershing platform. • Pershing also pays us a Basis Point Credit each quarter which is computed based on the total value of Stephens client accounts held on the Pershing platform. • Pershing also provides consulting and other assistance to us from time to time. • Stephens receives revenues from Pershing on any investor free credit balances. These revenues are not received by Stephens for free credit balances in Employee Retirement Income Security Act (“ERISA”) and Individual Retirement Account (“IRA”) accounts. • Stephens determines the margin debit interest rate and receives any amounts paid by customers in excess of the Fed Funds Target Rate plus 85 basis points. • Stephens determines the interest rate charged to clients who obtain non purpose loans within parameters set by Pershing. Stephens receives 100 bps of the interest paid on the loan from Pershing except in situations where Stephens has agreed to receive a lesser amount. • Pershing pays us a placement fee for each CD purchased through Pershing by a Stephens client. • Pershing pays us a portion of the revenues it receives for banking services provided to clients. For the period January 1, 2024 through December 31, 2024, Pershing paid Stephens the following revenues: Interest based on investor free credit balances of $1,900,734 • A short interest rebate $1,714,766 • • Margin interest credit of $836,256 • Active account and basis point credits of $1,563,496 • Non Purpose Loan interest of $617,507 • Silver Account (i.e. checking account) fee of $35,750 • Fee Income-Pershing-Legal/Transfer $7,600 • Pershing-Money Market Invesco ATRR $243,432 Where Stephens receives compensation from Pershing, this presents a conflict of interest because ADV Part 2A Appendix 1 March 31, 2025 8  Stephens and your IAR have a greater incentive to make available, recommend, or make investment decisions regarding investments and services that provide additional compensation over those investments and services that do not. The Clearing Agreement between Stephens and Pershing is for an initial term of 10 years, and it provides for a substantial termination penalty in the event Stephens terminates the clearing agreement prior to the end of the initial term. At the outset of the Clearing Agreement, the termination penalty was $15 million, and it declines $2 million each year to $5 million in years 6 through the end of the Clearing Agreement. The termination penalty serves as a disincentive for Stephens to terminate the Clearing Agreement in the event Stephens or its clients have a negative experience with Pershing or if Stephens believes another firm offers superior service. This creates a conflict of interest in that it could influence Stephens’ decision to remain with Pershing even though it may be in the best interest of Stephens or its clients to terminate the Clearing Agreement. You should only use the cost basis information provided on your custodial account statements for tax reporting purposes. Pershing’s mailing address is Pershing LLC; One Pershing Plaza; Jersey City, New Jersey 07399. For IRA and other retirement accounts, Pershing may charge termination fees pursuant to an adoption agreement you enter into with Pershing, which authorizes Pershing to act as the IRA custodian for Internal Revenue Service purposes. Pershing may resign at any time as the IRA custodian and then you have the right to appoint a successor IRA custodian (Successor). ERISA and IRA Fees Fees charged by Stephens to accounts of ERISA or Internal Revenue Code-covered plans will comply with the limitations made applicable under ERISA or the Code. Where Stephens or an IAR provides non-discretionary investment advice such as recommending the rollover of a 401k to an IRA account at Stephens, recommending opening an IRA account with Stephens, or recommending the transfer of an IRA from another firm to Stephens, this presents a conflict of interest since compensation will be paid to Stephens and the IAR in connection with these services. In addition, Stephens charges different levels of fees on different investment services. Stephens has adopted policies and procedures to mitigate these conflicts, and to address provisions of and prohibitions under ERISA and the Code with respect to potential conflicts of interest and self-dealing. ERISA Section 408(b)(2) Disclosures You may be, or may be acting on behalf of, a pension plan governed by the Employee Retirement Income Security Act of 1974, as amended (ERISA). ERISA section 408(b)(2), requires most parties that provide services to employee benefit plans to disclose certain information to a responsible plan fiduciary. Generally, the service provider must disclose the services that it provides to the plan and the compensation that it expects to receive in connection with the services. Stephens’ disclosures are available at the following web address: www.stephens.com/ERISA408b2 If you are the responsible plan fiduciary, please view the disclosures on this website. If you are not the responsible fiduciary, please forward this information to the responsible fiduciary of the plan. Please review this website periodically for any required updates. ADV Part 2A Appendix 1 March 31, 2025 9  Principal Transactions Pursuant to SEC Rule 206(3), Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing the capacity in which it is acting. As a practical matter, the above requirements impose delays on the time at which principal transactions can be effected for advisory accounts, and thereby can impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. Investment advisory clients are advised that they have the option to seek execution of transactions recommended by the IAR through broker-dealers other than Stephens. However, on transactions executed through Stephens with Pershing, Stephens or Pershing will not charge a commission to the client, except when an underwriting issue in which Stephens participates is purchased for an account; in this case, the sales concession and underwriting fees are built into the offering price. Stephens will strive to obtain “best execution” of transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances. Transactions in securities in which Stephens acts as a principal will only be affected for clients subject to the client’s written consent to such transaction indicating the quantity and dollar amount of the securities being purchased or sold. If Stephens is acting as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a client. Item 5 Account Requirements and Types of Clients Conditions for Management Generally, a minimum of $100,000 in assets is required for the establishment of investment advisory accounts under the SFIM program. However, exceptions may be made to this policy. Stephens or the client can terminate SFIM agreements at any time following advance written notice. Only those clients we deem in our discretion suitable will be accepted into this program. We provide investment advisory services to individuals, pension plans, foundations, corporations, other business entities and other types of clients Types of Clients Stephens’s advisory programs are available to individuals, banks, foundations, pension and profit sharing plans, trusts, IRA’s, endowments, corporations, partnerships and other entities requiring investment advisory services. Many of Stephens’ clients are high net worth individuals. We provide investment advice to individuals, trusts, boards and retirement systems for various governmental pension and retirement plans, corporate pension and retirement plans, various foundations and private entities. Additionally, Stephens advises wrap fee accounts in various programs sponsored by affiliated and unaffiliated investment advisers. The sponsor establishes a minimum account size for each program, and you should refer to the sponsor’s wrap fee brochure for a discussion of minimum account sizes and whether the minimum account size can be waived. Only those clients we deem in our discretion suitable will be accepted into these programs. Item 6 Portfolio Manager Selection and Evaluation ADV Part 2A Appendix 1 March 31, 2025 10  Education and Business Standards As a general rule, Stephens requires SFIM IARs to have a college degree and at least five years business experience with investment bankers, financial institutions, insurance companies, or equivalent institutions. Such standards may be waived in exceptional cases. All SFIM IARs are employees of Stephens. Performance Calculations A Portfolio Analysis report will be provided to the advisory client at least quarterly. The Portfolio Analysis report is organized to show the performance of the portfolio and the investments included in the portfolio. The portfolio performance is calculated monthly according to industry standards and compared to a comparable index based on product type and duration. SFIM can tailor Portfolio Analysis reports, and the sources of such reports, to suit client needs. Advisory Services Management of accounts in the SFIM program is overseen and reviewed by the Fixed Income Management Committee, which is composed of: David Moix Troy W. Clark Brian Baumeister Adam Ward Abigail Buchanan Portfolio Managers The Fixed Income Management Committee has delegated certain portfolio management responsibilities to the SFIM IARs. Our investment management service seeks to tailor an investment program for the unique financial circumstances and objectives of a particular client. When we are engaged as an investment manager, the client typically pursues one or more of our investment strategies. Clients can impose reasonable investment restrictions on the manager of their accounts, such as restrictions on investing in particular securities or types of securities or restrictions on investing in particular industries. Conflicts of Interest Conflicts of Interest Ownership Pursuant to SEC Rule 206(3), Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing the capacity in which it is acting. As a practical matter, the above requirements may impose delays on the time at which principal transactions may be effected for advisory accounts, and thereby may impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. Transactions in which Stephens acts as a principal will only be effected for clients subject to the client’s written consent to such transaction indicating the quantity and price of the securities being purchased or sold. If Stephens is acting as a market-maker or otherwise as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a client. ADV Part 2A Appendix 1 March 31, 2025 11  American Beacon Stephens Funds® and Hotchkis & Wiley Funds (“Affiliated Funds”) are funds managed by affiliates of Stephens and/or advisors in which affiliates of Stephens have a substantial ownership interest. ERISA accounts and IRA accounts are generally prohibited from investing in these Funds. Other advisory accounts may invest in the Affiliated Funds in an appropriate amount if: (1) the manager and the client determine that the investment is suitable for the account, and (2) the client signs an Affiliate Funds Consent Letter (“Consent Letter”) prior to directing the purchase of the affiliated fund shares. Hotchkis and Wiley Limited (“HW-UK”), a wholly-owned subsidiary of H&W, is a private limited company incorporated in England and Wales. HW-UK is an appointed representative and tied agent of Arlington Group Asset Management Limited (AGAM) since March 1, 2016. AGAM is authorized by the Financial Conduct Authority to carry out regulated activities. The Chief Executive of HW-UK is also an appointed representative of AGAM and may carry on certain regulated activities in Europe. Portfolio Management by Advisors Owned or Partially Owned by Stephens Affiliated Mutual Funds Stephens may from time to time engage in transactions on behalf of clients with Hotchkis & Wiley Capital Management LLC (“H&W”) or with mutual funds advised by H&W. H&W is an investment adviser registered with the SEC in which entities under common control with Stephens hold an ownership interest. H&W provides investment advisory services to corporate, pension, public, endowment, foundation, mutual fund and other clients, and H&W also advises its own family of mutual funds. Stephens may also from time to time engage in transactions on behalf of clients with Stephens Investment Management Group LLC (“SIMG”) or with mutual funds advised by SIMG. SIMG is an investment adviser registered with the SEC in which affiliates of Stephens hold the entire ownership of voting securities. SIMG provides investment advisory services for separate account clients and for mutual funds known as the American Beacon Stephens Funds® or other funds which may be added from time to time. Additionally, SIMG serves as one of the investment advisors to the following multi-manager mutual funds using its SMID Select Growth Strategy or Small Cap Growth Strategy: • Vanguard Explorer™ Fund; and • Bridge Builder Small/Mid Cap Growth Fund; and • First Trust Multi-Manager Small Cap Opportunities ETF (MMSC) H&W advised mutual funds and SIMG advised mutual funds are offered through Stephens’ broker dealer services and/or investment advisory services as part of an investment program. Clients that invest in H&W advised mutual funds or in SIMG advised mutual funds would bear a proportionate share of the fees and expenses of those funds including the management fees or other fees paid to H&W or SIMG. These fees and expenses include commissions or fees, if any, paid to Stephens in connection with portfolio transactions. Please refer to each mutual fund’s prospectus for a full discussion of the fees and expenses of each mutual fund. Stephens Sponsored Wrap Fee Program Stephens sponsors the Stephens Small-Mid Cap Core (“SMID Core”) Growth Program which is a wrap fee program sub-advised by SIMG that follows its SMID Core Growth Model. FCs are not financially incentivized to place clients in the SMID Core Growth Program versus any other wrap program or platform available at Stephens. However, a portion of the SMID Core account fees, generally ADV Part 2A Appendix 1 March 31, 2025 12  representing twenty to fifty percent (20%-50%) of SMID Core fees, will be paid to SIMG for its portfolio management services, pursuant to a sub-advisory agreement between Stephens and SIMG. SIMG and Stephens share common ownership, which benefits from the compensation generated to SIMG as the result of a client investing in the SMID Core Growth Program. Depending on the level of trading, the value of the account, and types of securities purchased or sold, clients may be able to obtain transaction execution at a higher or lower cost if purchased separately at Stephens or SIMG than through this wrap fee program. Affiliated Investment Management Activities Certain investment strategies offered by SIMG have been selected for inclusion in the Private Client Group’s (“PCG”) Managed Assets Program (“MAP”). Sub-Advisors and strategies may only participate in MAP if they have been approved by the MAP Investment Committee. The MAP Investment Committee employs a process for evaluating investment managers that includes both qualitative and quantitative factors. SIMG strategies participating in MAP are subject to the same due diligence and evaluation processes as sub-advisors or strategies that have no affiliation with Stephens. FCs are not financially incentivized to favor selecting SIMG strategies over non-affiliated sub-advisors or strategies. However, selection of an SIMG strategy in MAP generates compensation to SIMG, which shares common ownership with Stephens. Other Affiliations Certain entities affiliated with Stephens or under common control with Stephens hold an ownership interest in Alex Brown Realty, LLC, a registered investment adviser. From time to time, Stephens offers to its clients securities sponsored by Alex Brown Realty, LLC. Stephens sometimes refers clients to Stephens Insurance, LLC, an affiliated insurance agency under common control with Stephens, for advice pertaining to products that are provided through Stephens Insurance, LLC, and IARs may be eligible subject to regulatory and legal requirements, to receive referral fees for insurance business referred. For further information that pertains to related persons of Stephens, please refer to “Other Potential Conflicts of Interest”. Other Potential Conflicts of Interest Stephens is a diversified financial services company that directly or through affiliates provides a wide variety of investment banking, securities, insurance and other investment-related services to a broad array of customers. These relationships could give rise to potential conflicts of interest. Any of the following types of transactions could present a potential for a conflict of interest. • Client account assets can be invested in interests of money market funds, mutual funds, other investment companies, privately offered investment funds and other collective vehicles (collectively, “Funds”) for which Stephens or its affiliates may act as investment advisor, sponsor, administrator, distributor, selling agent, or in other capacities (“Affiliated Funds”). In addition, Client account assets can be invested in interests of Funds for which Stephens or its affiliates do not act as investment adviser, sponsor, administrator or in other capacities. Stephens or its affiliates receive fees for services provided to such Funds, which often include (but are not limited to) fees payable under a plan adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (“12b-1 fees”) and fees paid to compensate Stephens for providing administrative services, distribution services, shareholder services, investment advisory services or other services to or for the benefit of such Funds. Stephens as a dually-registered broker-dealer is paid the retail 12b-1 fees for brokerage mutual fund ADV Part 2A Appendix 1 March 31, 2025 13  investments. Where 12b-1 fees are received in advisory accounts, these fees are rebated to the client account. • From time to time, client account assets are invested in transactions that involve or constitute a purchase, sale or other dealings with securities or other instruments for which (i) Stephens, (ii) an affiliate or employee of Stephens, (iii) an entity in which Stephens or an affiliate has a direct or indirect interest, or (iv) another member of a syndicate or other intermediary (where an entity referred to in (i), (ii), or (iii), above is or was a member of the syndicate), has acted, now acts, or in the future may act as an underwriter, syndicate member, market maker, dealer, broker, principal, agent, research analyst or in any other similar capacity, whether the purchase, sale or dealing occurs during the life of the syndicate or after the close of the syndicate. Stephens has an incentive to favor the securities of issuers for which it provides such services over the securities of issuers for which Stephens does not provide such services. Your IAR also receives more money if you buy these investments. • From time to time, Stephens and its FCs and/or IARs may recommend that clients invest in investment products that are affiliated with Stephens. Such arrangements are described in greater detail above. Such a recommendation of affiliated investment products creates a potential conflict of interest because Stephens, its affiliates, and their beneficial owners may receive higher aggregate compensation than if clients invest in unaffiliated investment products. Stephens addresses this potential conflict through disclosure, including in this Brochure. Additionally, when acting as fiduciaries, Stephens FCs and IARs are required to recommend affiliated investment products only when they determine it is in the client’s best interest to do so. FCs or IARs are not financially incentivized to recommend Stephens- affiliated products over any other investment product available at Stephens. In no case are you under any obligation to purchase any products or services sold by us or our affiliates. • Although underwriting initial public offerings on behalf of corporate and other types of issuer clients is a regular part of Stephens’ investment banking business, the frequency, share price, number of shares available, and other characteristics of such offerings vary widely over time. For example, in some years Stephens may not participate as an underwriter, or in only a few, IPOs. • Stephens or any other broker-dealer that is or may become affiliated with Stephens (the “affiliated brokers”) is expected to act as broker or dealer to execute transactions on behalf of Client’s account. Client will not be charged a separate fee for brokerage services provided to the Account by affiliated brokers. • Stephens or its affiliates sometimes effect transactions for the client’s account with other accounts for which Stephens or an affiliate provides investment advisory services (“Cross Trades”). Such Cross Trades are intended to enable Stephens to purchase or sell a block of securities at a set price and possibly avoid an unfavorable price movement that may be created through entrance into the market with such purchase or sell order. Stephens typically receives compensation from other accounts involved in a Cross Trade. • Subject to applicable regulations, Stephens or its affiliates sometimes execute “Agency Cross Transactions” for the client’s account. Agency Cross Transactions are transactions where Stephens, or any affiliate of Stephens, acts as broker for both the client’s account and the other party to the transaction. In such transactions, Stephens, or any of Stephens’s affiliates acting as broker, receives commissions from the other party to such transaction, to the extent ADV Part 2A Appendix 1 March 31, 2025 14  permitted by law, in addition to its customary investment management or advisory fee for the client’s account. • Clients of other divisions of Stephens or clients of other advisory representatives of Stephens or Stephens, its principals, employees, affiliates and their family members, sometimes hold, and sometimes engage in transactions in, securities purchased or sold for the client or about which Stephens gives or has given Client advice. The client’s account may purchase as investments securities of companies with which Stephens or its affiliates maintain investment banking relationships or other relationships or securities of companies in which Stephens or its affiliates have an ownership or other investment interest. • Subject to applicable law, Stephens sometimes pays fees to, and/or shares revenues with, affiliates or non-affiliates in connection with referrals for investment advisory accounts. For additional information regarding referrals, please see Item 9. • Stephens or its affiliates may provide more than one type of service to the client (or a related organization), including (but not limited to), investment management services, investment advisory services, financial advisory services, underwriting services, placement agency services, investment banking services, securities brokerage services, securities custodial services, insurance agency services, insurance brokerage services, administrative services or other services, or any combination of services, all on such terms as may be agreed between Stephens (or its affiliate) and client (or its related organization). • Other divisions and other advisory representatives of Stephens perform investment advisory services for the clients other than client and such other divisions or other advisory representatives of Stephens give advice or take action with respect to other clients that is similar to or different from the advice given or action taken for the client’s account, in terms of securities, timing, nature of transactions and other factors. Stephens will, to the extent practicable, attempt in good faith to allocate investment opportunities among its clients, including the client, on a fair and equitable basis. However, other divisions and other advisory representatives of Stephens will not undertake to make any recommendation or communication to client with respect to any security which such other divisions or advisory representatives may purchase or sell (either as principal or for any other client’s account) or recommend to any other client, or in which such other divisions or advisory representatives , or their respective principals, employees, affiliates or their family members, may engage in transactions. • For ERISA accounts, when Stephens provides non-discretionary investment advice to the client regarding such an account, we are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we are compensated can create conflicts of interest, so we have established procedures which require us to act in the client’s best interest and not put our interest ahead of the client’s. • Both advisory and brokerage clients of Stephens have the ability to borrow money against the collateral value of their accounts with non-purpose loans arranged through Stephens with a third party bank. Stephens receives a fee which is paid by the third party bank in an amount which varies but can be up to 1.35% of the monthly outstanding balance of the client’s loan. Part of the administrative fee is passed along to Stephens Investment Fixed Income, and this can create a conflict of interest. Since Stephens has ADV Part 2A Appendix 1 March 31, 2025 15  not compared rates available elsewhere, clients may be able to obtain lower interest rates on their loans through other banks. • Stephens and Pershing and IntraFi receives fees and benefits for services provided in connection with the Bank Sweep Program. Stephens offers the Bank Sweep Program as a service and is not obligated to offer you this or any sweep product or to make available to you a sweep product that offers a rate of return that is equal to or greater than other comparable products or investments. Stephens has an economic incentive to make available to our clients sweep options that are more profitable to us than other sweep options. Each Bank will pay Stephens a fee equal to a percentage of the average daily deposit balance in your Deposit Accounts at the Bank. Because the Banks pay different amounts, the compensation paid to Stephens will vary from Bank to Bank. Because the interest rates paid to clients are subject to tiers based on the aggregate value of accounts within the client’s Household Balance, Stephens’ compensation rate is higher on client’s cash in lower interest rate tiers and lower on client’s cash balances in higher rate tiers. The differences in Stephens’ compensation from Bank to Bank is intended to ensure that all clients receive the same rate of interest on their Deposit Accounts for their respective interest rate tiers, regardless of the Banks at which the Deposit Accounts are held. Stephens may reduce its fee and may vary the amount of the reductions between clients. The interest rate applicable to your Deposit Account is determined by the amount of interest participating banks are willing to pay on the aggregate balance of the deposits minus: (i) the fees paid to Intrafi Network LLC, as administrator, (ii) the fees paid to Pershing for its services, and (iii) the fees paid to Stephens. Stephens retains and exercise the right to negotiate its own fee and may reduce or increase its fee. Because an increase in fees to Stephens reduces the effective amount of the interest rate that is ultimately paid to customers, Stephens has a conflict of interest with regard to the Bank Sweep Program. The tier applicable to your Deposit Accounts is determined based on your Household Balance as of the first business day following the fifteenth (15th) of the month. Stephens charges advisory accounts an investment advisory fee based on a percentage of client assets. In computing your investment advisory fee, cash balances in the Bank Sweep Program are included in the assets of your account when calculating the investment advisory fee earned by Stephens for management of your account. Therefore, Stephens is paid both its fee from the Banks on the Bank Sweep Program balance in your account, and, in addition, Stephens earns an investment advisory fee for your total balances in your account, including your balance in the Bank Sweep Program. This creates a conflict of interest, as Stephens earns more from Bank Sweep Program balances in investment advisory accounts than it would if such balances were held outside of the Bank Sweep Program or outside of the investment advisory account entirely, creating an economic incentive for Stephens to retain advisory assets in cash in the Bank Sweep Program. Your IAR does not receive a portion of the fee paid to Stephens by the Banks. • The Stephens Investment Banking department may introduce its clients, prospective clients, or affiliates thereof, to Stephens Financial Consultants. This introduction is done in Stephens’s capacity as a registered broker-dealer, and not as a registered investment advisor. If the introduction results in a new account relationship, then for a period of years a portion of the ADV Part 2A Appendix 1 March 31, 2025 16  net revenue from such account is allocated to the Investment Banking department as a referral fee. Such revenue is considered, along with other factors, in the determination of compensation for the introducing investment banker(s). This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. Conflict of Interest with Personal Trading and Client Trades To minimize potential conflicts of interest, advisory personnel who determine or approve what recommendations will be made for client accounts will not participate in Stephens’s proprietary trading activities and will not know what trading strategies are employed for its proprietary accounts. It should be noted, however, that Stephens allows purchases to be made in the marketplace by its employees of securities owned by any client account, provided that such purchases are made in amounts consistent with the normal investment practice of the person involved. Such purchases must be made after the investment advisory accounts managed by such employee (or in the management of which such employee participates) has completed its transactions in such securities. Under certain circumstances, employee transactions may be permitted prior to full completion of investment advisory division’s transactions. Such exceptions require prior approval of the Chief Compliance Officer or his designee and will only be granted after considering factors such as the time element involved in filling the order, market considerations, etc. Stephens Personal Trading Stephens’ personnel may not participate in IPOs. All employees are required to maintain their personal accounts and accounts in which they have a beneficial interest at Stephens unless the account has been specifically exempt in writing from this requirement. Stephens’ employees are required to provide copies of all of their trade confirmations and brokerage account statements to Stephens’ Compliance Department in order to permit the monitoring of compliance with personal trading policies and restrictions. Additionally, IARs are required to report all personal securities transactions no less than quarterly. Stephens’ Code requires employees to report violations of the Code to Stephens Chief Compliance Officer. Portfolio Management Description of Advisory Services Stephens’ investment advisory services seek to tailor an investment program for the financial goals and objectives of a particular client. When we are engaged as an investment advisor, the client typically pursues one or more of our investment strategies. Clients may impose reasonable investment restrictions on their accounts, such as restrictions on investing in particular securities or types of securities or restrictions on investing in particular industries. Except with respect to the payment of the fees or service charges or for correction of errors, Stephens is not authorized to withdraw or transfer any money, securities, or property out of a client’s account, without authorization from the client. Client acknowledges and understands that brokerage or securities transaction execution services provided by any person or entity other than Stephens or Pershing are separate from and in addition to the wrap fee for the account. Additionally, regular service charges shall apply to client’s account for brokerage services other than securities execution services provided by Stephens. Stephens and its affiliates performs advisory and/or brokerage services including investment reporting for various clients, and Stephens gives advice or take actions for other clients that differ from the advice given or the timing or the nature of any action taken for your account. In addition, Stephens may, but is not obligated to, purchase or sell or recommend for purchase or sale any security which Stephens or ADV Part 2A Appendix 1 March 31, 2025 17  any of its affiliates may purchase or sell for their own accounts or the account of any other client. Stephens and Pershing will not charge commissions on securities transactions that are executed through Stephens or Pershing for advisory accounts. Your account would be responsible to pay any commission charges imposed by any other brokerage firm on any securities transactions executed through any other brokerage firm, and such charges would be in addition to the wrap fee and any other applicable charges incurred by your account. By executing trades through Stephens with Pershing, your account might forego benefits, such as participation in block trades or negotiated transactions that might be available through other brokerage firms. For ERISA and IRA accounts, when Stephens provides non-discretionary investment advice to the client regarding such an account, we are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we are compensated can create conflicts of interest, so we have established procedures which require us to act in the client’s best interest and not put our interest ahead of the client’s. Stephens Insured Bank Sweep Program Stephens makes available to clients whose accounts are custodied at Pershing the opportunity to participate in the Bank Sweep Program. In this program all of the uninvested cash in a client’s account is automatically deposited, or “swept” into FDIC insured, interest-bearing deposit accounts at one or more banks which participate in the Bank Sweep Program. None of the banks participating in the Bank Sweep Program are owned by or affiliated with Stephens. For more information about the Bank Sweep Program please review these important disclosures at www.stephens.com/investment-disclosures/ which are incorporated by reference into this Form ADV Part 2A. Stephens offers the Bank Sweep Program as a service and is not obligated to offer this or any sweep product or to make available to a sweep product that offers a rate of return that is equal to or greater than other comparable products or investments. The interest rates paid on Deposit Accounts at a bank may be higher or lower than the interest rates available to depositors making deposits directly with the bank or other depository institutions in comparable accounts and for investments in other cash equivalent investments through Stephens. The Bank Sweep Program is not available to ERISA plans with accounts at Stephens such as employee benefit plans, retirement plans, defined contribution plans, defined benefit plans, (collectively, “ERISA accounts”) or to traditional and rollover IRA accounts, Roth, SEP, SIMPLE and inherited individual retirement accounts (“IRAs”); Keogh plans; and Coverdell education savings accounts. The Bank Sweep Program for your account should not be viewed as a long-term investment option. If you desire, as part of an investment strategy or otherwise, to maintain a cash position in your account for other than a short period of time and/or are seeking the highest yields currently available in the market for your cash balances, please contact your FC to discuss investment options that are available outside of the Bank Sweep Program to help maximize your return potential consistent with your investment objectives, liquidity needs and risk tolerance. Please note, however, that available cash accumulating in your account will not be automatically swept into any investment you purchase outside of the Bank Sweep Program. Nothing obligates you to participate in the Bank Sweep Program. You may receive a higher rate of return through products offered outside the Bank Sweep Program, including Money Market Funds offered through your account with Stephens and Pershing. Each Deposit Account constitutes a direct obligation of the Bank and is not directly or indirectly an ADV Part 2A Appendix 1 March 31, 2025 18  obligation of Stephens or Pershing. Stephens and Pershing do not guarantee in any way the financial condition of the Banks or the accuracy of any publicly available financial information concerning such Banks. You are responsible for monitoring the total amount of deposits that you hold with any one Bank, directly or through an intermediary, in order for you to determine the amount of deposit insurance coverage available to you on your deposits. Stephens and Pershing are not responsible for any insured or uninsured portion of a Deposit Account Wrap Fee Programs In addition to other indications of individual ownership, including the right to withdraw, hypothecate, vote, or pledge securities held in the wrap fee client’s account, a wrap fee client has the ability to place reasonable limitations and/or restrictions on the investments in their portfolio. Where restrictions are imposed, Stephens will manage the client’s portfolio investments to comply with these restrictions, but the investment performance of the client’s account will likely differ (positively or negatively) from other clients following a similar investment strategy, that is not subject to the same restrictions. The minimum account size for wrap fee programs vary from program to program, and a person considering a wrap fee program should review the disclosure document provided by Stephens of the applicable program for details regarding the operation of the program, its risks, fees, and other charges. In determining the suitability of an investment strategy for a particular wrap fee program client, we rely on the information provided by the client regarding the financial objectives of the client for each account. This information comes from, among other sources, personal interviews with the client and written questionnaires completed by the client and other communications with the client or its representative regarding the client’s situation, investment objectives, risk tolerances and investment restrictions, if any. Our strategies are not appropriate for all investors, and investors should only invest a portion of their portfolio in these programs. In certain programs we advise, we have the discretionary authority to determine the securities, and the amount of securities, to be bought and sold for our clients without obtaining specific client consent. The discretionary authority regarding investments may, however, be subject to certain restrictions and limitations placed by the client on transactions in certain types of securities or industries or to restrictions or limitations imposed by applicable regulations. Performance-Based Fees and Side-By-Side Management In the SFIM program, Stephens generally does not offer any performance-based fee alternatives. Stephens typically charges clients an investment advisory fee based on the value of the assets in the client’s account. On occasion, Stephens enters into performance fee arrangements with appropriate clients as discussed below. Only certain clients qualify for performance fee arrangements which compensate Stephens based, in part, on the performance of the client’s account. All fees are negotiable and vary depending on the size of the investment, the nature of the services to be rendered by Stephens to the client, and other factors. Performance fees are typically invoiced annually. Stephens only enters into performance fee arrangements with certain clients which are eligible to enter into these arrangements as defined in Rule 205-3 under the Investment Advisers Act of 1940 (the “Adviser’s Act”) and in accordance with the requirements set forth in applicable laws, rules and regulations, and these arrangements are negotiated with the client on an individualized basis. The performance fee arrangement could create an incentive for Stephens to seek to maximize the investment return by making investments that are subject to greater risk, or are more speculative, than would be the case if Stephens’ compensation were not based upon the investment return or could create an incentive ADV Part 2A Appendix 1 March 31, 2025 19  for Stephens to seek to limit investment returns by pursuing investments with reduced risk. With a performance fee arrangement Stephens’ fee is contingent upon the returns on the client’s assets, which are computed based upon unrealized and realized appreciation or depreciation of client’s assets. Accounts participating in a performance fee arrangement may pay Stephens more compensation, or less compensation, when compared to standard fee rates. Performance fee arrangements are not available for all investment accounts and must be approved by Stephens on a case- by-case basis. Performance fee rates are negotiable. A client may negotiate a base fee rate, performance fee rates, an index to be used to calculate the performance fee, or the use of no index in calculating the performance fee. Any performance fee that Stephens charges is intended to comply with Rule 205-3 and other applicable requirements under the Advisers Act of. Stephens has an incentive to favor accounts which it charges a performance fee over other types of client accounts by allocating more profitable investments to performance fee accounts or by devoting more resources toward the accounts’ management. Stephens seeks to mitigate the potential conflicts of interest which arise from managing accounts that bear a performance fee through its policies and procedures, including those related to investment allocation, and by complying with the provisions of Rule 205-3 as stated above. Stephens has discretion not to accept these arrangements. Methods of Analysis, Investment Strategies and Risk of Loss SFIM IARs currently provide investment advisory services for your discretionary portfolio. Your SFIM IARs have the flexibility to adapt strategies to a changing financial environment while maintaining a focus on long-term growth and capital appreciation. SFIM IARs are responsible for making day-to-day discretionary investment decisions subject to oversight and review by the SFIM Supervisory Principals. The SFIM program seeks to keep client assets fully invested at all times. Un-invested cash assets may be included in the Bank Sweep Program, or for ERISA or IRA accounts, in a money market mutual fund. We utilize street and independent sources for our research, but it is not the sole basis of our investment decision making process. Other sources of information we utilize can include industry data obtained from subscription services, company filings, street research and models. We utilize these services for real-time news and pricing. We also utilize other independent research sources for quantitative reports that measure such things as price changes, growth rates, profitability, valuation, earnings surprises and earnings revisions. These quantitative reports are used to help identify new securities that meet our investment criteria and to monitor existing holdings. Investing in securities involves risk of loss that clients should be prepared to bear. The material risks associated with our strategies are: Debt Obligations - Investing in debt (bond) obligations entails additional risks, including interest rate risk such that when interest rates rise, the prices of bonds and the value of bond funds shares can decrease and the investor can lose principal value. Management Risk - Our judgments about the attractiveness and potential appreciation of a particular asset class or individual security may be incorrect and there is no guarantee that individual securities will perform as anticipated. The price of an individual security can be more volatile than the market as a whole and our investment thesis on a particular stock may fail to produce the intended results. Money Market Risk - An investment in a Money Market Fund is not insured or guaranteed by the ADV Part 2A Appendix 1 March 31, 2025 20  Federal Deposit Insurance Corporation or any other government agency. Although the fund seeks to preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in the fund. Yields will vary. Yield quotations more closely reflect the current earnings of the fund than the total return. Investors should only invest a portion of their total portfolios in these securities, and investors should be prepared to lose their entire investments. Certain Risks Associated with Cybersecurity. With the increased use of technologies to conduct business, investment advisers, including Stephens rely in part on digital and network technologies (collectively, “cyber networks”). These cyber networks are susceptible to operational, information security and related risks and can be at risk of cyber-attacks. Cyber-attacks could seek unauthorized access to cyber networks for the purpose of misappropriating sensitive information, corrupting data, or causing operational disruptions. Cyber-attacks can potentially be carried out against the issuers of securities you have invested in, against third party service providers, or against Stephens itself by persons using techniques that range from efforts to circumvent network security, overwhelm websites, and gather intelligence through the use of social media in order to obtain information necessary to gain access to cyber networks. Although cyber-attacks potentially could occur, Stephens and Pershing maintains an information technology security policy and technical and physical safeguards intended to protect the confidentiality of internal data. Bank Sweep Program If you have on deposit through the Bank Sweep Program an amount of cash that exceeds the number of Banks multiplied by $250,000, the balances in excess of this amount will not be insured by the FDIC. In the event of a failure of a bank participating in the Bank Sweep Program, there may be a time period during which you may not be able to access your cash. If you have cash at a bank outside the Bank Sweep Program, this may negatively impact the availability of FDIC insurance for the total amount of your funds held within and outside the Bank Sweep Program. You are responsible for monitoring the total amount of deposits that you hold with any one Bank, directly or through an intermediary, in order to determine the extent of FDIC insurance coverage available to you on your deposits, including the Deposit Accounts. Item 7 Client Information Provided to Portfolio Managers Information about the client is communicated to the portfolio managers on the initial opening of the advisory account. A New Account Form is completed for or by the advisory client and maintained by Stephens. The New Account Form contains account name and address, investment objectives and specific financial information. Advisory account information is updated upon notification from the advisory client of any material changes and noted within the customer file. The SFIM IAR assigned to manage the account and support personnel have access to the client’s data maintained by Stephens. Stephens’ advisory programs are available to individuals, banks, foundations, pension and profit sharing plans, trusts, IRAs, endowments, corporations, partnerships and other entities requiring investment advisory services. Stephens is largely an investment adviser to high net worth individuals. We provide investment advice to individuals, to trusts, to boards and retirement systems for various governmental pension and retirement plans, to corporate pension and retirement plans, to various foundations and private entities. ADV Part 2A Appendix 1 March 31, 2025 21  Item 8 Client Contact with Portfolio Managers Client Meetings The SFIM IAR assigned to a client’s account will be the primary contact for the client at Stephens. SFIM IARs must offer to discuss or meet with clients periodically to discuss their investment portfolios and investment goals, not less frequently than annually. Clients are encouraged to contact their SFIM IAR at any time if the client would like to have additional discussions or meetings. If you have experienced any changes regarding your finances, investment objectives or risk tolerance, please contact your IAR to see if any adjustments are necessary to your investment strategy. Item 9 Additional Information Disciplinary Information Stephens voluntarily participated in the SEC’s Share Class Selection Disclosure Initiative, and on March 11, 2019 the SEC entered a Cease and Desist Order against Stephens in which Stephens neither admitted nor denied the allegations of the SEC’s Order. The Order alleged that Stephens did not fully disclose conflicts of interest related to the selection of mutual fund share classes for its advisory clients, and that Stephens purchased, recommended or held mutual fund share classes for client accounts which paid Stephens 12b-1 fees when less expensive share classes of the same funds were available which did not pay Stephens these 12b-1 fees. The Order directed Stephens to Cease and Desist from committing or causing any violations and any future violations of Sections 206(2) and 207 of the Investment Advisers Act of 1940 and ordered that Stephens be censured and pay disgorgement and prejudgment interest to advisory clients who held these more expensive mutual funds share classes in their advisory accounts. (IA Release No. 40-5196) In its capacity as a broker-dealer, Stephens has been subject to legal or disciplinary events in the ordinary course of its business, such as regulatory sanctions relating to compliance with broker-dealer trade reporting requirements and other regulatory actions. Affiliations Stephens, from time to time, enters into arrangements with other broker-dealers, investment advisors or other persons whereby such parties refer clients seeking advisory services to Stephens. For additional information regarding Stephens’ affiliations, please see Item 6 “Conflicts of Interest” above. Investment Advisory Code of Ethics Stephens has adopted an Investment Advisory Code of Ethics (“Code”), which defines the requirements and expectations for the business conduct of all of its Investment Advisory employees, including employees of Stephens. Furthermore, all Stephens’ employees are expected to adhere to Stephens’ Mission and Values Statement and Code of Professional Conduct. The fundamental position of Stephens is that all aspects of its business are to be conducted in an ethical and legal manner in accordance with federal law and the laws of all states where the investment advisory divisions do business. In accordance with that position general principles apply: • The interests of Stephens’ clients are our first consideration. Any personal securities ADV Part 2A Appendix 1 March 31, 2025 22  transaction, which would be detrimental or potentially detrimental to any client account and any personal securities transaction, which is designed to profit by the market effect of any client account, must be avoided. • • All personal securities transactions should be conducted in such a manner as to be consistent with the Code and to avoid actual or potential conflicts of interest or abuse of a Stephens’ employee’s knowledge of customer information or customer transactions. Investment adviser personnel should not take inappropriate advantage of their positions. Information concerning the identity of security holdings and financial circumstances of clients is confidential. Independence in the investment decision-making process is paramount. • Accordingly, there are certain standards of conduct, which Stephens investment advisory employees follow to reduce potential conflicts with the interests of our clients. Stephens will provide a copy of the Code to any client or prospective client upon request. Supervision and Review of Accounts Primary responsibility for the supervision of these accounts lies with SFIM Supervisory Principals. David Moix is responsible for supervisory approval of new advisory accounts and the daily review of trading activity. The Supervisory Principal review consists of monthly analysis of activity in SFIM accounts considering suitability and general performance. The portfolio manager calculates returns based upon pricing provided by an outside source. The calculations are compared to certain indices, which are chosen by SFIM pursuant to investment guidelines dictated by the client. In addition to the monthly reviews, regular quarterly reviews of the total value of the account and assets in each security and category are completed. The reviewers may refer accounts to the Compliance Department for further analysis if necessary. When Stephens executes a transaction for you through a Perishing order execution system, you will receive a written or electronic confirmation of the transaction which provides information regarding the transaction. You may elect to receive these quarterly. You will also receive a written or electronic monthly account statement if you had activity in your account that is custodied by Pershing during the month, which will detail the activity and the positions in your account. If you have not had any activity during the month and you have positions in your account, you will receive a written or electronic quarterly account statement, which details the positions in your account. You may waive the receipt of account statements or confirmations after each trade in favor of e- delivery via stephensaccess.netxinvestor.com/nxi/login . You may also receive mutual fund prospectuses, where appropriate. In addition, we provide account reports for client accounts reflecting account holdings and account performance on a quarterly basis. Client Referrals and Other Compensation Neither Stephens nor any of our employees receives any sales awards or other prizes from any non- affiliated outside parties for providing investment advice to our clients. Stephens may enter into referral arrangements with its affiliates or between divisions of the Firm. This includes referrals to Stephens of prospective clients seeking investment advisory services. If the referral results in a new account relationship, then a portion of the net revenue from such account is paid to ADV Part 2A Appendix 1 March 31, 2025 23  such entity or division as a referral fee, and such entity or division may pay some portion of the fee to the referring person. This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. Such arrangements are conducted in accordance with the Marketing Rule, as applicable, and the Advisers Act generally. FCs are eligible to receive referral fees for referring eligible clients to the Stephens Investment Banking division. For eligible investment banking referrals, referring parties are eligible to receive compensation as a percentage of net income earned by Investment Banking. Therefore, FCs are incentivized to refer clients to the Investment Banking division. Any such compensation to the FC is at the discretion of the Firm. Financial Information Stephens does not require or solicit prepayment of more than $1200 in fees per client six months or more in advance and, thus, has not included a balance sheet of its most recent fiscal year. Stephens is not aware of any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to our clients. Who to Contact We are pleased to have an opportunity to serve as your investment adviser. If you have any questions about the information contained in this brochure or about any aspect of the services we provide, please do not hesitate to call Stephens at (877-891-0095). Clients often receive this information by electronic delivery. The Stephens ADV and additional brochures are available at www.stephens.com/investment- disclosures/. To access your Advisory Representative's SEC Advisor Biography, go to www.stephens.com , use the search bar in the top right corner of the home page and search by your Advisory Representative's name. SEC Advisor Biographies are also available in the "Our Team" section and are there for your review. ADV Part 2A Appendix 1 March 31, 2025 24  Definitions and Professional Designation Qualifications Accredited Investment Fiduciary® (AIF®) The Accredited Investment Fiduciary (AIF®) Designation is a professional certification that demonstrates an advisor or other person serving as an investment fiduciary has met certain requirements to earn and maintain the credential. The purpose of the Accredited Investment Fiduciary (AIF®) Designation is to assure that those responsible for managing or advising on investor assets have a fundamental understanding of the principles of fiduciary duty, the standards of conduct for acting as a fiduciary, and a process for carrying out fiduciary responsibility. The AIF® training curriculum is offered in distance education or a blended learning option to suit each Candidate's needs. Fi360’s Prudent Investment Practices cover four Steps (domains), twenty- one Practices (tasks), and seventy-nine Criteria that an investment fiduciary is expected to be able to perform. After passing the exam, a Candidate wishing to file for the AIF® designation must submit the accreditation application and accreditation fee. Six Hours of annual continuing education is required, a minimum of four of which must be delivered by Fi360 or one of Fi360's approved CE providers. Accredited Wealth Management AdvisorSM (AWMA® ) Individuals who hold the AWMA® designation have completed a course of study encompassing wealth strategies, equity-based compensation plans, tax reduction alternatives, and asset protection alternatives. Additionally, individuals must pass an end- of-course examination that tests their ability to synthesize complex concepts and apply theoretical concepts to real-life situations. All designees have agreed to adhere to Standards of Professional Conduct and are subject to a disciplinary process. Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standards of Professional Conduct and complying with self-disclosure requirements. The Chartered Financial Analyst (CFA) The CFA Institute is an international non-profit organization whose stated mission is to promote and develop a high level of educational, ethical and professional standards in the investment industry. To be eligible for the CFA designation, candidates must pass 3 examinations that test the academic portion of the CFA program, possess a bachelor’s degree from an accredited educational institution or equivalent, and have 48 months of acceptable professional work experience. The CFA curriculum includes the following subject areas: Ethical and Professional Standards; Quantitative Methods (such as the time value of money, and statistical inference); Economics; Financial Reporting and Analysis; Corporate Finance; Analysis of Investments (such as stocks and bonds); and Portfolio Management and Analysis (asset allocation, portfolio risk, and performance measurement). CERTIFIED FINANCIAL PLANNER™ (CFP®) To earn the CFP® designation, an individual must complete a college-level course of study addressing the financial planning subject areas determined by the Certified Financial Planner Board of Standards, Inc. (“CFP Board”), pass a comprehensive two-day examination developed by the CFP Board and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university) and demonstrate three years of full-time work experience in financial planning or a related field. CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income ADV Part 2A Appendix 1 March 31, 2025 25  tax planning, retirement planning, and estate planning. Once the CFP® has attained the CFP certification, they are require to complete 30 credit hours of continuing education accepted by CFP Board every two years, including 2 hours of CFP Board-approved ethics continuing education. Chartered Financial Consultant® (ChFC®) The ChFC® Program offers comprehensive education in the essentials of financial planning, including insurance, taxation, retirement, and estate planning. It also addresses advanced areas such as behavioral finance, non-traditional family structures, and small business planning. There are no prerequisite courses required before you can begin the ChFC® Program, but to use the designation, you are required to have three years of full-time, relevant business experience and a high school diploma or the equivalent. To receive and maintain the ChFC® designation, you must agree to comply with The American College Code of Ethics and Procedures and participate in the annual Professional Recertification Program (PRP) to maintain the designation. Certified Investment Management Analyst (CIMA) The CIMA certification signifies that an individual has met initial and on-going experience, ethical, education, and examination requirements for investment management consulting, including advanced investment management theory and application. Prerequisites for the CIMA certification are three years of financial services experience and an acceptable regulatory history. To obtain the CIMA certification, candidates must pass an online Certification Examination. The Certification Examination is a five-hour examination and has 125 multiple-choice questions and 15 non-scored, pretest questions. Each examination item (question) is related to an area of work performed by an investment management consultant/advisor. The topics have been identified through a job analysis. All examination items are written in a four-option, multiple-choice format. CIMA designees are required to adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and Guidelines for Use of the Marks. CIMA designees must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through Investment Management Consultants Association (IMCA). ADV Part 2A Appendix 1 March 31, 2025 26  Certified Pension Consultant (CPC) The Certified Pension Consultant (CPC) credential is conferred by ASPPA to benefits professionals working in plan administration, pension actuarial administration, insurance and financial planning. CPCs work alongside employers to formulate, implement, administer and maintain qualified retirement plans. The CPC is the capstone credential, or highest credential, currently conferred by ASPPA. To earn the CPC credential, you must successful complete various exams, verify a minimum of two years’ experience in the retirement plan industry, provide two letters of recommendation and apply for the ASPPA credentialed membership. All credentialed members must acquire 40 hours of continuing education (CE) credits (2 of which must be Ethics) in a two-year cycle and renew their ASPPA Membership annually to retain their credential(s). The Certified Portfolio Manager (CPM®) The Certified Portfolio Manager (CPM®) designation is a collaboration of the Academy of Certified Portfolio Managers and Columbia University. The academic component is designed to provide a deeper understanding of fundamental security analysis, asset allocation, and portfolio management concepts for financial services industry professionals managing discretionary portfolios. The curriculum encompasses eight core concepts: • Quantitative Methods • Financial Statement Analysis • Corporate Finance • Fixed Income Analysis • Equity Analysis • Fiduciary Responsibility • Derivatives • Qualifying for the CPM® designation • The current criteria for applicant eligibility are any of the following (1) A certificate, diploma or academic degree providing evidence of a four-year undergraduate degree (2) 3 years of employment in the financial services industry and (3) Letter of recommendation on behalf of the applicant who is employed in the financial services industry, written by a supervisor, where the credential requirements are desired for the training and development of the applicant. At the end of each calendar year, ACPM members are required to submit the following; Record of 20 completed continuing education hours. ACPM maintains a self-auditing continuing education policy. Answers to a series of Professional Conduct questions. Annual membership dues. All three items are due by December 31st of that calendar year. ADV Part 2A Appendix 1 March 31, 2025 27  Certified Public Accountant (CPA) CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally include minimum college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting), minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA), and successful passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of continuing professional education (CPE) activities on an ongoing basis. Additionally, all American Institute of Certified Public Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct. Chartered Retirement Planning Counselor SM (CRPC®) The CRPC® is conferred by the College for Financial Planning. Individuals who hold the CRPC® designation have completed a course of study encompassing pre-and post- retirement needs, asset management, estate planning and the entire retirement planning process using models and techniques from real client situations. Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standard of Professional Conduct and complying with self-disclosure requirements. Chartered Retirement Planning Specialist SM (CRPS®) The CRPS® is conferred by the College for Financial Planning. Individuals who hold the CRPS® designation have completed a course of study encompassing the specialization in creating, implementing and maintaining retirement plans for businesses. They must pass an exam demonstrating their expertise. Successful applicants earn the right to use the CRPS designation with their names for two years. Designees renew their designation every two- years by completing 16 hours of continuing education, reaffirming adherence to the Standard of Professional Conduct and complying with self-disclosure requirements. Qualified Plan Financial Consultant (QPFC) QPFC is the professional credential for financial professionals who sell, advise, market or support qualified retirement plans. The QPFC program provides an understanding of general retirement planning concepts, terminology, distinctive features of qualified plans and the role of retirement plan professionals. QPFC is for professionals with two to three years of retirement plan experience. A candidate will be expected to demonstrate a general proficiency of plan administration, compliance, investment, fiduciary, and ethics issues. The QPFC credential is available as an alternative to the CPFA® credential. The coursework and exam are the same for both credentials. Candidates must complete the NAPA CPFA® exam, agree to abide by the ARA Code of Professional Conduct, and apply for the credential. In order to maintain the credential, designees must complete 10 CE hours per calendar year, starting the year following when the designation was earned. ADV Part 2A Appendix 1 March 31, 2025 28