Step Advisers is an SEC registered investment adviser that was formed in June 2022. The Firm is wholly owned by Step Mobile, Inc. (“Step”). Step Advisers provides internet-based non-discretionary investment advisory services with respect to securities held in accounts of adults (age 18 and older) (each a “Client,” and collectively, “Clients”) who are users (each a “User,” and collectively “Users”) of a mobile application offered by Step (the “Step app”). A User of the Step app is not a Client of Step Advisers unless and until they enter into an Investment Advisory Agreement with the Firm, as defined below. Step Advisers’ investment advisory services are tailored to teenagers (age 13 through age 18) and adults to buy and sell securities curated by the Firm. With respect to teens under 18, this is accomplished through the implementation of a written trading authorization (“Trading Authorization”) that authorizes Client’s teenage children (including teenage children for whom they serve as legal guardians) who are users of the Step app (each a “Teen Investor” and collectively, “Teen Investors”) to invest among a curated selection of securities recommended by the Firm, subject to the Client’s control and monitoring, such as enabling or disabling a Teen Investor’s ability to make investments and setting dollar limits on trading. Clients retain legal ownership of the account and may revoke the Teen Investor’s Trading Authorization at their sole discretion. Step Advisers interacts with Clients and Teen Investors predominantly through a software application that is available through the Step app, and its advisory services are delivered solely through the Step app. Step Advisers does not provide investment advice in person, over the phone, or in any manner other than through the Step app. Step Advisers maintains an online presence through www.step.com, primarily for informational purposes. To enter into an advisory relationship, a Client is required to agree to an investment advisory agreement with Step Advisers (“Investment Advisory Agreement”), which discusses the services the Client will receive, the fees charged to the Client (as applicable), and the conditions of the Client’s relationship with Step Advisers. The Firm’s advisory relationship with a Client begins upon the effective date of the Investment Advisory Agreement with a Client. Any preliminary information provided to a Client before the Firm accepts the Investment Advisory Agreement does not constitute investment advice under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and should not be relied on as such. A Client must also open a securities brokerage account and provide non-discretionary authority over such accounts to Step Advisers. Brokerage accounts, agreements, and order processing is conducted through DriveWealth, LLC (“Custodian”), an unaffiliated SEC-registered broker-dealer and Financial Industry Regulatory Authority (“FINRA”) Step Advisers, LLC -5- Firm Brochure member, which provides brokerage related services to Step Advisers and Clients within the Step app. Custodian also provides custody, clearing, and settlement services for Step Advisers’ Clients. Using Custodian’s application program interface (“API”), the Step app allows Clients to create an investment account instantly on any mobile device. Custodian

buys and sells supported securities assets, stores securities assets acquired by Clients, and tracks securities transactions via the Step app. The investments in each Client’s account are held in a separate account in their name at Custodian, and not with Step Advisers. Through a questionnaire in the Step app, Clients provide personal information about themselves, including financial resources, income information, and employment status, and each Client provides information about their investment goals and/or risk tolerance. Step Advisers utilizes the information from the questionnaire responses to create investment recommendations customized to the risk tolerance (“Investment Needs”) of each Client. Step Advisers evaluates each Client’s responses and makes recommendations aligning with these Investment Needs. The investment recommendations made by Step Advisers for each Client are based solely upon the information provided to the Firm through the Step app. As such, the suitability of the Firm’s investment recommendations is limited by and relies on the accuracy and completeness of the information provided by the Client. Step Advisers does not capture any additional information not covered in the questionnaire in making its risk assessment and providing its investment advice. Clients are obligated to update their information through the Step app promptly if there are changes to their financial situation, goals, objectives, personal circumstances or if other relevant information changes or becomes available. Step Advisers’ investment advisory services consist of non-discretionary investment recommendations made to Clients by the Firm through the Step app. The Firm’s recommendations consist of curated buckets of equity securities, and American Depositary Receipts (“ADRs”) and exchange traded funds (“ETFs"), sorted according to risk (Low Volatility, Moderate Volatility, High Volatility). Clients and Teen Investors, subject to the limitations imposed by Trading Authorizations, as applicable, are responsible for determining the securities for Clients’ portfolios and proceeding with transactions from among the securities in the buckets for which the Client is eligible based on their Investment Needs. Step periodically updates the securities within the buckets and advises Clients when securities held in their portfolios are no longer consistent with their Investment Needs. Step Advisers has non-discretionary authority to effect securities transactions on behalf of Clients, as described above. Non-discretionary trading authority permits Step Advisers to effect transactions to buy or sell securities with the prior consent of the Client or, where permitted by a Trading Authorization, the Teen Investor. Such prior consent is required for each transaction recommended by Step. Clients and Teen Investors are limited to purchasing securities within buckets for which the Client is eligible based on their Investment Needs. Step Advisers, LLC -6- Firm Brochure Step Advisers does not provide comprehensive financial or tax planning or legal advice, and Clients are advised and afforded the opportunity to seek the advice and counsel of the Client’s own tax, financial, and legal advisers. The Firm’s services are not a complete investment program and Clients should not use it as the sole component of their investment plan. The Firm does not have assets under management as of the date of this Brochure.