Firm Description Verdis Investment Management, LLC (“Verdis”) was founded in 2004 and has been in business for eighteen (18) years. Verdis provides management services and investment advisory services to the partners of Verdis Investment Management and their family members: (i) on a discretionary basis, to certain privately placed pooled investment vehicles (“Verdis Funds”) and (ii) on a discretionary or non-discretionary basis, to separately managed accounts (“Separate Accounts”) and wealth advisory clients (“Wealth Advisory Accounts” or “Wealth Advisory Services” or “Account”). Clients of such are “Clients” or “Advisory Clients.” Verdis Funds services are described in detail in a separate Form ADV Part 2. This Form ADV Part 2 addresses the firm’s discretionary or non- discretionary Wealth Advisory Account services. Wealth Advisory Accounts are managed, pursuant to a discretionary or non-discretionary Investment Management Agreement (IMA), in the agreed upon form and in accordance with the Client’s stated investment objectives, strategies, restrictions and guidelines. Verdis Funds’ generally follow a “fund-of-funds” model, investing assets with or through third-party investment managers (each a “Manager”). Verdis generally places a portion of a Funds’ account’s assets (“Account”) in a “sleeve account” managed by the Manager or invests the Account into a pooled fund managed by the Manager (in each case, a “Vehicle”). Verdis screens each Vehicle through a rigorous due diligence process and active, ongoing monitoring. Ownership The majority of Verdis is owned by parent company ViosCapital, LLC, which is owned and comprised of only Jamie Biddle, Partner and CEO, and Steve Kim, Partner, Investment Strategy & Risk Management. Type(s) of Services Offered Verdis’ Wealth Advisory Services are currently offered exclusively to Verdis’ principals, employees and their respective family members/family entities. Through Wealth Advisory Services, Verdis determines appropriate asset allocation models and builds portfolios using investments in non-Verdis Vehicles as well as Verdis’ Funds. Depending on the arrangement with a Client,

Verdis will make recommendations with respect to asset allocation and third-party investment managers (each a “Manager”), or a pooled fund managed by the Manager (in each case, a “Vehicle”), either directly to the Client or to the custodian or trust company used by the Client. Verdis’ systems have been designed to work with their Client’s providers of custodian and banking services, allowing Verdis to provide Wealth Advisory Clients advanced reporting capabilities to track Manager performance, monitor risk, and provide a comprehensive, aggregated view of the Client’s net worth by, among other things, presenting consolidated position information. Wealth Advisory Clients who invest in Verdis Funds may be granted information rights that are superior to those offered to other Clients. The firm, along with each advisory Client, will produce an initial Investment Policy Statement (IPS). Verdis’ advice to Wealth Advisory Accounts may include general advice as to the investment of the Client’s Account, and may include recommending that such Clients invest through or alongside Verdis Funds. The IPS will be updated annually as the Client’s needs evolve over time. The IPS is intended to confirm the Client’s investment goals and certain management policies that will be applicable to the Client’s assets. It will also memorialize any restrictions that the Client wishes to place on the investment manager. The IPS will:
• Describe relevant circumstances;
• Describe the assets and accounts for which Verdis will be providing investment advice;
• Describe expected cash flow needs, time horizon and risk/return objectives for those assets and accounts;
• Reflect current asset allocations and establish acceptable target allocations;
• Once those targets are achieved, recommend and discuss rebalancing practices;
• Establish guidelines for judging the performance of the portfolio and the selected investment managers. Assets Under Management As of December 31, 2022, Verdis managed $59.6 million in discretionary assets in Wealth Advisory Accounts, not including Wealth Advisory Clients’ investments in the Verdis Funds.