Invictus Fiduciary Services, LLC

Invictus Fiduciary Services, LLC is a financial advisory firm established in July 2016 and registered with the SEC in January 2017. The firm specializes in serving as an Investment Manager or Advisor to Employee Stock Ownership Plans (ESOPs). Invictus offers services in three capacities: as an Investment Manager to ESOPs on an ongoing basis, in transactions involving the purchase or sale of company stock by the ESOP, and providing investment advisory services to ESOP trustees and Plan Sponsor Fiduciaries. The firm's fee structure includes an annual fee based on the fair market value of ESOP assets, with a minimum annual fee of $15,000. Invictus also charges a distribution transaction fee and reimburses reasonable out-of-pocket expenses incurred in connection with services provided. The firm does not charge performance-based fees or engage in side-by-side management. Invictus emphasizes fiduciary responsibility and maintains a Code of Ethics outlining firm policies on insider trading, conflicts of interest, and personal securities transactions. The firm does not receive soft dollar benefits from broker-dealers and does not compensate third parties for client referrals. Invictus has custody of client accounts when a member serves as a trustee and maintains discretionary authority. Clients are encouraged to review account statements from the custodian for accuracy. Invictus does not accept proxy voting authority for client securities. The firm received a loan under the Payroll Protection Program in 2020 due to income loss from Covid-19, but has no other financial commitments that may impair meeting contractual obligations.