Item 4B - Types of Advisory Services .......................................................................................1 Item 4D - Wrap Fee Programs ...................................................................................................3 Investment Advisory Agreement ...............................................................................................3 Item 5 - Fees and Compensation.................................................................................................. 4 Item 5A - Description ................................................................................................................4 Item 5B - Fee Billing .................................................................................................................5 Item 5C - Other Fees ..................................................................................................................5 Item 5D - Prepayment ................................................................................................................6 Item 5E - Commissions ..............................................................................................................6 Item 6 - Performance-Based Fees & Side-by-Side Management.............................................. 6 Sharing of Capital Gains ............................................................................................................6 Item 7 - Types of Clients ............................................................................................................... 6 Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss .................................. 7 Item 8A - Methods of Analysis ..................................................................................................7 Item 8B - Investment Strategies .................................................................................................7 Item 8C - Risk of Loss ...............................................................................................................8 Item 9 - Disciplinary Information ............................................................................................. 11 Legal and Disciplinary .............................................................................................................11 Item 10 - Other Financial Industry Activities and Affiliations............................................... 11 Item 10A/ 10B – Registrations and Other Registrations .........................................................11 Item 10C - Affiliations .............................................................................................................11 Item 10D - Other Advisers .......................................................................................................12 TOC 2 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading......................................................................................................................................... 12 Item 11A - Code of Ethics .......................................................................................................12 Item 11B, 11C, 11D - Participation or Interest in Client Transactions ....................................13 Item 12 - Brokerage Practices .................................................................................................... 13 Item 12A - Selecting Brokerage Firms ....................................................................................13 Item 12B - Order Aggregation .................................................................................................16 Item 13 - Review of Accounts ..................................................................................................... 16 Item 13A - Periodic Reviews ...................................................................................................16 Item 13B - Review Triggers ....................................................................................................17 Item 13C - Regular Reports .....................................................................................................17 Item 14 - Client Referrals and Other Compensation .............................................................. 17 Item 14A – Other Compensation .............................................................................................17 Item 14B - Referrals.................................................................................................................17 Item 15 - Custody ........................................................................................................................ 18 Item 16 - Investment Discretion................................................................................................. 18 Item 17 - Voting Client Securities.............................................................................................. 19 Item 17A - Proxy Votes ...........................................................................................................19 Item 18 - Financial Information ................................................................................................ 19 Item 18A, 18B, 18C - Financial Information ...........................................................................19

Additional Disclosure: Business Continuity Plan .................................................................... 20 Additional Disclosure: Information Security Program ........................................................... 20 Item 4A - Firm Description Victrix Investment Advisors LLC, (“Victrix”, “Firm” or “We”) was founded in 2013. Victrix provides investment advisory services to individuals and trusts. The principal owner of the Firm is William D. Thompson IV. William D. Thompson IV is also the Managing Member & Chief Compliance Officer (CCO) of Victrix. Victrix is a fee-only investment advisory firm. An evaluation of each client's initial situation is provided to the client, often in the form of a net worth statement, risk analysis or similar document. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are engaged directly by the client on an as-needed basis and may charge fees of their own. Victrix, its representatives or any of its employees will disclose to the clients all material conflicts of interest. Victrix provides investment advisory services through consultations. ASSET MANAGEMENT Victrix offers discretionary and non-discretionary asset management services to advisory clients. Victrix will offer clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. Victrix will determine for discretionary accounts the securities to be bought or sold and the amount of the securities to be bought or sold. For non-discretionary accounts, Victrix will obtain prior client approval on each and every transaction before executing any transactions. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. At the outset of each asset management relationship, Victrix’s Investment Advisor Representatives (“IAR”) spend time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and reviewing options for the client. Based on its reviews, Victrix generally develops with each client a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile”) and the client’s investment objectives and guidelines (the “Investment Plan”). The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments Victrix will make or recommend on behalf of the client to meet those goals. The Profile and the Plan are discussed regularly with each client but are not necessarily written documents. FINANCIAL PLANNING AND RETIREMENT PLAN CONSULTING Clients can engage Victrix to perform financial planning service and Retirement Plan consulting. For such engagements, clients will compensate Victrix on an hourly fee basis described in detail under “Fees and Compensation” section of this brochure. Financial planning is a collaborative process that helps maximize a client’s potential for meeting goals through financial advice that integrates relevant elements of the client’s personal and financial circumstances. Financial planning services include but are not limited to a thorough review of all applicable topics including Investments, Qualified Plans, and Insurance. Specific topics within these three categories may include savings rate, Roth conversions, and life insurance coverage. A written financial plan is generated through a financial planning software package and delivered to the client by the IAR. The client is under no obligation to act upon the investment advisor’s recommendation. If the client elects to act on any of the recommendations, the client is under no obligation to affect the transaction through Victrix. Financial plans will be completed and delivered inside of sixty (60) days. Clients may terminate financial planning and/or retirement plan consulting service with written notice. Victrix will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below, as and when requested by the client. Victrix will provide Plan Fiduciaries with recommendations of investment options consistent with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination of investment options and for compliance with ERISA section 404(c). We provide Plan Fiduciaries and Plan Participants general, non-discretionary investment advice regarding assets classes and investments. We may also assist in monitoring the plan’s investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and will make recommendations to maintain or remove and replace investment options. The details of this aspect of service will be enumerated in the engagement agreement between the parties. 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. The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objectives. Upon mutual agreement between the Advisor and client, clients may impose restrictions on investing in certain securities or types of securities. Examples include but are not limited to excluding alcohol and tobacco companies. The Firm does not engage in any Wrap Fee Programs. As of December 2022, Victrix manages approximately $109,151,910in assets for approximately 754 accounts. Approximately $109,127,309is managed on a discretionary basis (representing 752 accounts), and $24,601is managed on a non- discretionary basis (representing 2 accounts). Investment Advisory Agreement The scope of work and fee for a client is agreed upon in an Investment Advisory Agreement that is signed by the client prior to the start of the management of any client assets. This agreement provides detailed information concerning what services are provided, the scope and limitations of these services, how fees are paid, disclaimers around the potential risks involved with investing, liability, confidentiality, etc. Although the Investment Advisory Agreement is an ongoing agreement, the length of service to the client is at the client’s discretion. A client may terminate the investment advisory relationship by written notice at any time without penalty. At termination, any paid but unearned fees will be promptly refunded to the client based on the number of days that the account was managed, and any fees due to Victrix from the client will be invoiced or deducted from the client’s account prior to termination. Financial Planning and Retirement Plan Consulting clients may terminate the relationship by written notice at any time without penalty. At termination, any fees due to Victrix from the client will be invoiced based on the number of hours spent up to the time of termination.