A. Description of the Advisory Firm Tickeron, Inc. (hereinafter, “Tickeron”) is a privately-held Nevada corporation formed in January 2013 by Sergey Savastiouk and John Jacques. Messrs. Savastiouk and Jacques and SAS Worldwide, Inc. are the principal owners of Tickeron. B. Types of Advisory Services Tickeron provides investment advisory service through a secure website (“Website”) which can be found at www.Tickeron.com. Specifically, Tickeron provides users with the ability to create and manage one or more hypothetical investment portfolio(s) of comprising stocks, bonds, exchange traded funds (“ETFs”), real estate investment trusts (“REITs”), cryptocurrency, and foreign exchange transactions (“Forex”). Registered users (“Members” or “Clients”) undergo a registration process in terms of which said users create a profile and are each assigned a username and password for registered access to the Website. The class of Members is further divided into Beginner Members, Intermediate Members, Expert Members. Each type of Member corresponds to a certain level of proficiency in making investments. Ideally said level of proficiency increases from low to high as follows: Beginner Member, Intermediate Member, Expert Member. Generally, a Beginner Member has little or no investment experience; an Intermediate Member is someone with moderate investment experience; an Expert Member is someone with substantial investment experience. Members are required to self-classify themselves into one of the classes of Members, failing which they are classified as Beginner Members by default. Tickeron does not verify that Beginner, Intermediate, or Expert Members are properly classified into a class based on the Member’s level of investment proficiency. Expert Member are allowed to sell investment advice to other Members as will be described. Elements of the investment advisory service include:
• Portfolio Diversification Scores: A portfolio’s “Diversification Score” allows a Member to determine whether said member’s portfolio is adequately diversified or if it needs additional diversification. The Diversification Score is generated by a proprietary, automated computer algorithm, which analyzes various inputs submitted by a Member, such as the length of investment term, risk tolerance and the Member’s existing portfolio.
• AI Robots and/or Portfolio Allocation Tools: The investment advisory service provides tools to generate a “Investment Allocation” and a “Trade Ideas” for a portfolio. The Investment allocation is recommended for Members that reallocate portfolio holdings infrequently. The Trade Allocation is recommended for Members that reallocate portfolio holdings frequently. A portfolio’s Investment Allocation and/or Trade Allocation are generated by a proprietary, automated computer algorithm, which analyzes various inputs submitted by a Member, such as the length of investment term, risk tolerance and the Member’s existing portfolio. Based on a Diversification Score, Investment Allocation, and Trade Allocation for a portfolio, a Member may determine how or whether to change said portfolio by taking independent action or seeking investment advice from third parties.
• Marketplace: In addition to providing Members’ portfolio(s)’ with Diversification Score(s), Investment Idea(s) and/or Trade Idea(s), the Website also allows certain Members to interact with other members. In practical the Website has a virtual the “Marketplace”, which allows all Members to subscribe to publications and/or purchase investment-related products from Expert Members.
• Webcasts: An Expert Member are allowed to create a web conference room (“Webcast”) to allow other Members to follow said Expert Member’s trading activity by means of web- based screen sharing. Webcasts are enabled on a pay-per-view basis or free.
• Investors or Trader Clubs: An Intermediate Member, Expert Member can each create a virtual group (“Investors Club or Trader”) comprising other Members who are invited to join the Investors or Trader Club. The creator of an Investors or Trader Club is allowed to manage allocations of a Club Portfolio. The Website provides functionality to allow Members of an Investors or Trader Club to communicate between themselves using communication tools such as instant messaging. Said Members are each allowed to maintain a version of the Club or Trader Portfolio and to suggest their versions of Club Portfolio allocations by re-allocating their versions of the Club Portfolio. Members can make visible their personal portfolios to other Members of an Investor Club. Members of an Investor or Trader Club may view AI and Community predictions on securities that are a part of the Club Portfolio.
• Member Profiles: The Website allows each Member to maintain a Member Profile which is, in essence, a social media-style profile comprising posts corresponding to the Member’s activities such as publishing an Article in Blogs, creating a Webcast, etc. Members can view the profiles of other Members. A Member can also subscribe

to be notified of updates from another Member.
• Tickeronker Profile Screener: Akin to Member profiles, Tickeronkers may also have profiles (“Tickeronker Profiles”). A Tickeronker represents a tradable investment such as a stock, mutual fund, ETF, etc. A Member can browse the Tickeronker Profiles published on the Website. Each Tickeronker profile comprises information such Tickeronker market information, financial indicators, messages associated with the Tickeronker, blog posts associated with the Tickeronker, tweets about the Tickeronker, AI and Community Trend Predictions for the Tickeronker (see below)
• Community Trend Predictions and Voting: The Website provides functionality for Members to make predictions about price movements associated with a Tickeronker or with a portfolio of Tickeronkers. The predictions may be captured through polling of Members to determine a Members prediction. Said polling may be achieved through a voting feature whereby a Member is allowed vote on whether the Member thinks that a Tickeronker or portfolio of Tickeronkers is going to go up or down.
• Academy: The Website provides Academy wherein Members are able to communicate with each other and view articles about Tickeronkers and portfolios.
• Patterns and Trends and AI Robots: The Website provides access to a Pattern and Trend Search Engines which allow Members to receive Alerts of recognized patterns or trends od trades in their Inboxes and track the bookmarked securities. Clients of Tickeron may connect their brokerage accounts to Tickeron and trade in their accounts by clicking buy/sell using Tickeron's buttons. Tickeron will not have any custody of any assets. Robo-Advisory Portfolio Management Services Tickeron provides “robo-advisory” services through an online interface. This entails the use of algorithm-based portfolio management advice, but asset management rather than in-person investment advice. These automated investment solutions are customized to each client and based on individual Characteristics, such as the client’s risk tolerance, time horizon, and current assets, among others. Tickeron’s investment advisory personnel oversee the algorithm but may not monitor each client’s account. Clients are encouraged to maintain their AI Robots and portfolios questionnaires with any change in their objectives, risk tolerance, or other pertinent information, as that information factors into the portfolio’s composition or AI Robot or portfolio selection. Services Limited to Specific Types of Investments Tickeron generally limits its investment advice to mutual funds, equities and ETFs. Tickeron may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions Tickeron provides online “robo-advisory” portfolio services. Client accounts are generally invested into a target allocation depending on the client’s individual profile per portfolio or a robot. This automated approach factors in client financial situation and risk tolerance, although the algorithms used to provide advisory services are designed to be utilized by Tickeron across multiple clients. Tickeron may manage Client-Defined Portfolios or Robots which are Investment Profiles customized by the client based on the model portfolios and themed portfolios designed by Tickeron. Client-Defined Portfolios will be managed in accordance with the investment allocation selected by the client through an online interface. Clients may impose restrictions in investing in certain securities or types of securities in accordance. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. Tickeron does not participate in wrap fee programs. E. Assets Under Management Tickeron has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $0 $0 December 2024