OneDigital - retirement Plan Investment Management Agreement - 06.01.2026 - SIGNED
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OneDigital Page 10 Form ADV, Part 2A Company LLC; Donald L. Hagan, LLC; and WisdomTree Asset Management, Inc. and/or their affiliates (collectively, “Model Managers”) provide OneDigital with investment research, models and/or technology at no cost, which is used in the development and maintenance of various investment models offered to OneDigital’s non-retirement plan clients. OneDigital’s receipt of these benefits, however, creates a conflict of interest for OneDigital because it reduces OneDigital’s operating costs, which, in turn, creates an incentive for OneDigital to recommend Model Managers’ products and/or services to clients, including to retirement plan clients of OneDigital. OneDigital addresses these conflicts of interest by (1) providing disclosure of the relationship and the associated conflicts of interest to clients in this Disclosure Brochure and (2) reminding clients that they have the ability to impose reasonable restrictions on the securities or types of securities to be held in their portfolios, including a restriction on the purchase and/or use of Model Managers’ products and/or services. Mariner, LLC (“Mariner”, CRD No. 140195): OneDigital has entered into a Solicitor’s Agreement with Mariner, an investment adviser, pursuant to which OneDigital is compensated by Mariner for referrals of prospective investment advisory clients. In light of this compensation arrangement, clients should be aware that OneDigital has a conflict of interest when recommending the investment advisory services of Mariner. Sub-Advisers: OneDigital has entered into agreements with various unaffiliated third-party investment advisers for the provision of discretionary investment sub-advisory services offered through the Personalized Portfolios program. Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading OneDigital maintains a Code of Ethics that includes (1) standards of business conduct that all of our supervised persons are expected to adhere to; (2) a prohibition on insider trading; (3) provisions relating to the receipt and giving of gifts, and (4) policies and procedures requiring the periodic reporting of personal securities transactions and holdings. As our client or prospective client, you are entitled to a copy of our Code of Ethics upon request. You may request a copy by contacting us at (877) 742-2021. OneDigital and/or its supervised persons may buy or sell securities that are also held by or recommended to clients and may occasionally trade in securities in a personal account, at or about the same time that OneDigital trades in the same security, or a related security, for a client account. When either of these situations occur, conflicts of interest exist because OneDigital and/or its IAR(s) (1) may have an incentive not to recommend the sale of those securities to clients in order to protect the value of a personal investment (2) may have an incentive to recommend the purchase of those securities to clients in order to immediately sell it at a profit in a personal account upon the rise in market price (i.e., scalping) and (3) may have an incentive to place personal investment orders before those of clients in order to obtain a better price and/or otherwise materially benefit from the purchase or sale of those securities (i.e., front run). When engaging in personal trading, we believe that our clients’ interests should come first, and our supervised persons are reminded of OneDigital’s fiduciary duty and their obligation to comply with OneDigital’s standards of business conduct. Additionally, OneDigital monitors the personal