Page 4 A. Ownership/Advisory History Innovis Asset Management LLC (the "Company," "we" and/or the "firm") is a Delaware limited liability company founded in 2022 with its principal place of business in Illinois. The Company became registered as an investment adviser in 2022. Chad Whiteley is the owner of the Company. B. Advisory Services Offered The following paragraphs describe the services offered by the Company. Please refer to the following paragraphs for more detail about the specific service, and how we tailor our services to your individual needs. As used in this Brochure, the words "our" and "us" also refer to the Company. The words "you," "your" or "client" refer to our clients and prospective clients. Other terms may be defined later in this Brochure as well. Investment Advisory Services The Company offers continuous and ongoing investment advice and portfolio management services. Our advice and services are tailored to meet our client's individual needs, life circumstances and investment goals. We have discussions with the client at least annually to understand client goals, income, return objectives, risk tolerance, time horizons and liquidity needs. We use the information we gather to create an Investment Policy Statement (IPS) which guides an individualized investment portfolio for the client and customized asset allocation across the Company’s active strategies. Account management and supervision is guided by the client's IPS, investment portfolio, and market conditions. We manage clients' investment accounts on a discretionary basis. Once we construct an investment portfolio for a client, we will monitor the portfolio's performance on an ongoing and continuous basis, unless otherwise agreed, and will adjust and reallocate as necessary due to changes in market conditions and the client's circumstances as communicated to us. For our discretionary asset management services, the Company will receive a limited power of attorney to effect securities transactions on behalf of a client. Pursuant to an agreement with a client, we may agree to limitations on our discretionary authority. Such limitations would not, however, be typical. We explore different types of investment options and strategies in the design of a client's customized investment portfolio. Our investment recommendations are not limited by any specific product or service offered by a broker-dealer or custodian. These recommendations will generally include, but not necessarily be limited to, security types from the following list: ▪ Mutual fund shares ▪ Exchange traded fund shares ▪ Public securities ▪ Separately managed accounts Page 5 ▪ Money market funds and other cash instruments ▪ Debt securities Each type of security has its own unique set of risks associated with it, and it would not be possible to list here all the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it. Because some types of investments involve certain additional degrees of risk, they

will only be recommended and implemented when consistent with the client's investment portfolio. Although we may discuss private equity securities with a client and review private placement memorandums at the client's request, we will not make specific recommendations as to whether a client should buy, sell or hold private equity securities. Clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio (must be in writing and sent to the firm), and should promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. The Company will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. The Company will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Third-Party Money Managers As part of our investment advisory services, we may recommend a third-party money manager to manage a portion of the client's investment portfolio. Factors we take into consideration when making our recommendation include, but are not limited to, the money manager's performance, investment strategies, methods or analysis, advisory fees and other fees, assets under management, and the client's financial objectives and risk tolerance. We would generally retain authority to hire/fire the third-party money manager, and we regularly monitor the performance of the money manager to ensure its management and investment style remain aligned with the client's objectives and risk tolerance. The Company continuously manages any third-party money manager relationship and continuously monitors the client's account(s) for performance metrics and adherence to the client's IPS. Each third-party money manager maintains a separate disclosure document that will be provided directly to the client from the third-party money manager. The client should carefully review the third-party money manager's disclosure document for information regarding fees, risks and investment strategies, and conflicts of interest. The third-party money manager will charge fees to the client, which fees will be in addition to the fees charged by the Company. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. Page 6 D. Wrap Fee Programs The Company does not participate in wrap fee programs, where brokerage commissions and transaction costs are included in the asset-based fee charged to the client. E. Client Assets Under Management As of December 31, 2023, the Company managed $1.8 million of discretionary assets. Item 5: Fees and Compensation