This Disclosure document is being offered to you by Fidelis Wealth Advisors, LLC (“Fidelis” or “Firm”) about the investment advisory services we provide. It discloses information about our services and the way those services are made available to you, the client. Fidelis is an investment management firm located in Castle Rock, Colorado. Fidelis Wealth Advisors’ services include investment management, financial planning and consulting services. We specialize in investment advi- sory services for individuals, high net worth individuals, pension and profit sharing plans, employee sponsored retirement plans, charitable organizations, trusts, estates, and corporations. Our Firm became a registered in- vestment adviser in May 2018. Samuel Rey Tenney is the Managing Member and Chief Compliance Officer of Fidelis Wealth Advisors and owns 92% of the firm. Ben Tenney owns 4%. The remaining 4% is owned by Teutates Financial, LLC a single member LLC owned by Lorie Jones. We are committed to helping clients build, manage and preserve their wealth, and to provide assistance that helps clients to achieve their stated financial goals. We will offer an initial complimentary meeting upon our dis- cretion; however, investment advisory services are initiated only after you and Fidelis execute an Investment Management Agreement. INVESTMENT AND WEALTH MANAGEMENT SERVICES We manage advisory accounts on a discretionary and non-discretionary basis. For discretionary accounts, once we have determined a profile and investment plan with a client, we will execute the day-to-day transactions without seeking prior client consent. Account supervision is guided by the written profile and investment plan of the client. We will accept accounts with certain restrictions, if circumstances warrant. We primarily allocate client assets among various equities, bonds and other fixed income securities, along with exchange traded funds, cash, unit investment trusts and no-load funds and/or load-waived funds (front-end commissions will not be charged) in accordance with their stated investment objectives. All of which are considered asset allocation categories for the client’s investment strategy. Each portfolio will be initially designed to meet a particular investment goal which Fidelis Wealth Advisors has determined to be appropriate to the client’s circumstances. Once the appropriate portfolio has been determined, we will review the portfolio and rebalance the account based upon our client’s individual needs, stated goals and objectives. Fidelis Wealth Advisors’ strategy, generally, will be to seek to meet client investment objectives while providing clients with access to personal advisory services. Fidelis Wealth Advisors may also provide advice about any type of legacy position or other investment held in client portfolios. It is the client’s obligation to notify us immediately if circumstances have changed with respect to their goals. Once we have determined the types of investments to be included in your portfolio and allocated them, we will provide ongoing investment review and management services. This approach requires us to periodically review your portfolio. With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet your financial objectives. We trade these portfolios based on the combination of our market views and your objec- tives, using our investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. You will have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of securities. If a non-discretionary relationship is in place, calls will be placed presenting the recommendation made and only upon your authorization will any action be taken on your behalf. You may make requests or make suggestions regarding the investments made in your portfolio. Restrictions on trading which, in our opinion, are not in your best interest cannot be honored and if forced may result in the termination of our agreement. In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees from your accounts, but only with the appropriate written authorization from you. Retirement Plans (ERISA), depending on the type of plan and how it is arranged, Fidelis Wealth Advisors may or may not have discretionary control of retirement plans’ assets or their accounts and it is clearly set forth in the plan agreement. Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically, these are assets that are ineligible to be custodied at our primary custodian. Clients will engage us to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance, annuity contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in cap- ital losses in your account. FINANCIAL PLANNING SERVICES Fidelis Wealth Advisors offers a broad range of financial planning and consulting services for our clients. Planning services can be provided on a stand-alone basis, or in conjunction with our investment management services. Financial Planning includes, in all or part, but is not limited to, the preparation of a financial plan for an investment advisory client which may include reviews and recommendations on any or all of the following areas depending on the Client’s circumstances:
• Investment Planning
• Investment Policy Statements
• Portfolio Review and Evaluation
• Budgeting and Cash Flow Planning
• Debt Management
• Capital Needs Analysis (Goal Funding)
• Risk Management/Insurance Analysis
• Employee Benefits
• Tax Management & Planning
• Trust and Estate Planning
• Charitable Giving
• Education Planning
• Social Security
• Retirement Planning
• Specific product due diligence (such as Real Estate Investment Trusts - REIT’s or Delaware Statutory Trusts – DST’s) Financial planning services can vary and is customized depending on each client’s complexity and circumstances. The financial planning services will be defined and agreed upon by both parties in advance. For example, a client’s not using Fidelis Wealth Advisors investment management services may request a comprehensive finan- cial plan, or certain components of our planning services. The amount of time it could take to provide each of the financial planning services will depend on the client’s unique circumstances and will vary from client to client. Our services are customized based on what a client may request. In addition, the amount of time it takes to provide these services is dependent on the quality and scope of the information that is provided by the client to the advisor. A comprehensive financial plan based on the process below generally takes between 20 to 30 hours. 1) ESTABLISH/DEFINE RELATIONSHIP WITH CLIENT – This includes meeting with clients to discuss Fidelis Wealth Advisors’ service offerings. We will also spend time learning about the Client’s situation, goals, ob- jectives, attitudes and values and overall satisfaction with the Client’s current financial situation. Fidelis Wealth Advisors may use risk tolerance software (Riskalyze) to gauge client risk tolerance. 2) DATA GATHERING – Fidelis Wealth Advisors will work with the Client to collect necessary data regarding multiple aspects of a Client’s financial situation and, where applicable, confer with outside financial profes- sionals with whom the Client may be working. 3) ANALYZE CLIENT SITUATION AND DEVELOP INITIAL RECOMMENDATIONS a. Budgeting and Cash Flow Planning – We will review income and expenses. We work with the Client to establish a view of both their current and future cash in and out flows to help see where adjustments and saving need to be made. We will address any concerns the Client may have currently or that we may foresee occurring in the future. b. Portfolio review and evaluation – After completing a risk tolerance questionnaire with the Client, we ensure investment accounts are properly diversified, in line with stated goals and objectives, and risk assumed is in line with Client’s objectives and comfort level. We review fees to verify fees being charged are not excessive, review tax consequences of overall portfolio structure and of specific transactions. We will review stock options (where applicable). We may make recommendations to rebalance employer sponsored retirement programs (where applicable). c. Insurance analysis – We will review insurance policies in force, including life, disability, property and casualty, and long-term care for needs and coverage gaps. d. Employee benefits review -- We review the Client’s benefits package to ensure they are taking full advantage of offerings available (where applicable). e. Tax management – Review of Client’s tax returns and coordinate with Client’s CPA or Tax advisor to integrate tax planning with their overall financial plan and investment strategies. We also conduct analysis to coordinate tax efficient withdrawal strategies in retirement. We do not prepare taxes. f. Estate plan review – We review documents currently in place and make recommendations for the need to complete or revise missing or outdated documents in with Client’s legal professional. g. Charitable giving – In cases where the Client has charitable intentions, we will review and provide charitable planning strategies. We will work with the Client’s legal professionals and/or CPA to implement the strategies the client elects to adopt. h. Social Security analysis – We analyze the optimal time for each spouse to begin benefits, in coordination with other retirement income sources. i. Pension/Annuity analysis (if applicable) – We help determine the appropriate timing to begin receiving withdrawals, and appropriate method for taking withdrawals. j. Retirement Planning – We work together to craft a strategy to help the Clients move toward their retirement goals. We conduct retirement cash flow planning. We determine a tax efficient withdrawal sequence. We review the feasibility of Roth IRA conversions. k. Testing Variables – We stress test the Client’s situation against potential future events (e.g., a long-term care need, increase in expenses, increase in inflation, portfolio returns) 4) INITIAL RECOMMENDATION PRESENTATION a. We present our initial findings to client and discuss the findings. b. We prepare custom scenarios a client may request (for example, wanting to retire early or purchase a vacation home. 5) IMPLEMENTATION OF FINANCIAL PLANNING RECOMMENDATIONS a. We work with clients to prioritize recommendations and put the recommendations into place. This may involve making a recommendation to an outside financial professional such as an attorney, accountant, or insurance agent. b. We will meet with the outside financial professional along with the Client if a more advanced strategy is being contemplated (such as substantial gifting) 6) MONITOR AND REVIEW a. Monitor cash flow – income, expenses, and spending if requested by the Client. b. Provide an annual review of tax returns and update Client information. We discuss any questions we may have regarding their tax situation. c. Provide investment account monitoring/rebalancing/suggestions for tax efficiency, d. Consult when new financial situations arise. This may include new investment opportunities; new major purchases; changes to insurance; modifications to estate plan; or new desires for gifting. e. We will meet with clients either in person, web meeting or conference call as needed. Clients always have the right to decide whether to engage the firm for financial planning services. Clients are encouraged to review their plans on a regular basis. Fidelis

Wealth Advisors has a conflict of interest because it offers both financial planning and investment man- agement services. When providing financial planning services, Fidelis Wealth Advisors has an incentive to rec- ommend itself for investment management services as Fidelis Wealth advisors receives additional compensation. Fidelis mitigates this conflict of interest by disclosing this conflict to you and disclosing that client always have the right to decide whether to engage Fidelis Wealth Advisors for Investment Management Services. Our fiduci- ary obligation is to always act and recommend in the clients’ best interest. RETIREMENT PLAN ADVISORY & CONSULTING SERVICES The Retirement Plan Advisory Services we offer help employer plan sponsors to establish, monitor and review their company’s retirement plan. As the needs of the plan sponsor dictate, areas of advising could include in- vestment selection and monitoring plan structure and participant education. Our Firm provides its advisory services as an investment advisor as defined under Section 3(21) and Section 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). We offer investment manage- ment of 401(k) accounts, profit sharing plans and defined contribution plans on a Plan level by managing the investment line-up making changes as necessary. Our Firm will establish the plan’s needs and objectives through an initial meeting to collect data, review plan information and assist in developing or updating the plan’s provi- sion. Ongoing services may include recommendations regarding the selection and review of unaffiliated mutual funds that, in the Firm’s judgment, are suitable for plan assets to be invested. We periodically review the invest- ment options selected and make recommendations to keep or replace plans investment options as appropriate. For employer-sponsored retirement plans, we provide advisory services as an investment advisor as defined un- der Section 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). When serving as an ERISA 3(38) investment manager, the plan sponsor is relieved of all fiduciary responsibility for the investment decisions made by our Firm. We are the discretionary investment manager in accordance with the terms of a separate ERISA 3(38) Investment Management Agreement between our Firm and the plan sponsor. Our investment management is limited in that it has the discretion solely to replace funds in plan fund lineups and initiate the transfer of existing balances to the replacements without prior approval from the client. Additionally, our Firm offers Retirement Plan Consulting Services to our Plan Sponsors. Our Firm may assist the Plan Sponsor by acting as a service provider liaison, providing participant enrollment meetings, and assisting with participant education. While the primary clients for these services will be pension, profit sharing and 401(k) plans, we offer these services, where appropriate, to individuals and trusts and organizations. Pension Consulting Services are comprised of four distinct services. Clients may choose to use any or all of these services. § SELECTION OF INVESTMENT VEHICLES - We assist plan sponsors in constructing appropriate asset allocation models. We will then review various mutual funds (both index and managed) to determine which investments are appropriate. The number of investments to be recommended will be determined by the client. § MONITORING OF INVESTMENT PERFORMANCE - We monitor client investments continually, based on the procedures and timing intervals detailed in the Investment Policy Statement. Although our Firm is not involved in any way in the purchase or sale of these investments, we supervise the client's portfolio and will make recommendations to the client as market factors and the client's needs dictate. § PARTICIPANT ENROLLMENT - We will assist Plan Sponsor in enrolling Plan participants in the Plan, including conducting an agreed upon number of enrollment meetings. As part of such meetings, we will provide participants with information about the Plan, which may include information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of preretirement withdrawals on retirement income, the terms of the Plan, and the operation of the Plan. § PLAN EDUCATION - We will assist participant education, which may include the preparation of education materials and/or conducting investment education seminars and meetings for Plan Participants. Such meetings may be on a group and/or individual basis. Such meetings shall not include specific investment advice about investment options under the Plan as being appropriate for a particular participant but may include the use of education investment models. Plan participants have the ability to exercise control over the assets in their account, and we have no authority or discretion to direct the investment of assets of any participant’s account under the Retire- ment Plan Consulting services offered by our firm. § ADDITIONAL INFORMATION CONCERNING PENSION & RETIREMENT PLAN CONSULTING - All pension consulting services shall be in compliance with applicable State rules and statutes and/or the Investment Advisers Act of 1940, rules and regulations thereunder regulating the services provided by this Agreement. This section applies to an Account that is a pension or other employee benefit plan (a “Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the Account is part of a Plan and we accept appointments to provide advisory services to such Account, Adviser acknowledges that it is a fiduciary within the meaning of Section 3(21) of ERISA (but only with respect to the provision of services described in section 1 of this agreement). Client represents that (i) Adviser’s appointment and services are consistent with the Plan documents, (ii) Client has furnished Adviser true and complete copies of all documents establishing and governing the Plan and evidencing your authority to retain Adviser. Client further represents that he/she/it will promptly furnish Adviser with any amendments to the Plan, and Client agrees that, if any amendment affects our rights or obligations, such amendment will be binding on Adviser only with our prior written consent. If the Account contains only a part of the assets of the Plan, Client understand that Adviser will have no responsibilities for the diversification of all the Plan’s investments, and Adviser will have no duty, responsibility or liability for the assets that are not in the account. If ERISA or other applicable law requires bonding with respect to the assets in the account, Client will obtain and maintain at his/her/its expense bonding that satisfies this requirement and covers Adviser and any of our affiliates. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the mean- ing of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. ESTATE PLANNING SERVICES Wealth.com provides a holistic estate planning solution that allows users to create, manage and administrate es- tate plans through a technology platform.  Wealth.com facilitates an optional hybrid model where clients can start the process digitally, but still receive a bespoke human experience by consulting live with one of the affiliated Trust and Estate attorney partners for a fee. Advisors purchase access to the Wealth.com platform as an annual license and can then invite or refer an unlimited number of clients to the platform for estate plan- ning. Wealth.com allows Clients to create estate planning documents to action their legacy objectives. Once referred to Wealth, my client enters the Wealth platform and is guided through the document creation process by Wealth, not by the advisor. Though advisors can refer clients to the platform, Fidelis Wealth Advisors is not involved with the drafting of the legal documents and do not have the ability to make selections for the client.  As an advisor, we can receive read-only visibility of the Client account to help ensure they complete the process of creating and continue to monitor for optimization opportunities. From a compliance standpoint, offering a Wealth.com account to a client is no different from any other estate planning referral an advisor can make.  Wealth.com prioritizes advisor compliance with industry best practices regarding legal ethics and professional rules of conduct. Wealth.com works with attorneys who are nationally recognized experts in advising technology firms seeking to structure ethically compliant relationships with con- sumers of legal services and governmental regulators.  CONSULTING SERVICES Fidelis Wealth Advisors provides a wide array of customized consulting services which may vary greatly in depth and scope and may be offered in a variety of different situations or circumstances that relate to your financial picture. We may consult with you regarding topics that are not covered under our general financial planning services or may not rise to the level of financial planning in the extent of data-gathering and breadth and depth of recommendations. We may consult on such items as a real estate purchase, a sale analysis, or a review of a financial account. Financial accounts may be accounts that are held at other firms or qualified retirement ac- counts held through the Client’s employer. The scope and cost of our consulting services are defined in writing prior to the engagement and will depend on the complexity of the situation. Consulting services will be offered to any client who the advisor deems to have circumstances that could be aided by our consulting services. Some factors in this determination may be the advisor’s experience and level of expertise with the situation. Clients always have the right to decide whether to engage the firm for consulting services. THIRD-PARTY MONEY MANAGERS Occasionally our Firm utilizes the sub-advisory services of a TPMM for the management of client accounts. Sub- advisors are utilized by Fidelis to offer funds to clients managed to a specific investment objective. The client will not engage the subadvisor directly; the client’s advisory relationship remains with Fidelis Wealth Advisors as set forth in the client’s Investment Advisory Agreement. Our Firm will not offer advice on any specific securities or other investments in connection with this service. Prior to utilizing sub-advisors for our clients, our Firm will pro- vide initial due diligence on third-party money managers and ongoing reviews of their management of client accounts. In order to assist in the selection of a TPMM, our Firm will gather client information pertaining to fi- nancial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. Our Firm will periodically review third-party money manager reports provided to the client at least annually. Our Firm will contact clients from time to time in order to review their financial situation and objectives, communicate information to third-party money managers as warranted, and assist the client in understanding and evaluating the services provided by the TPMM. Clients will be expected to notify our Firm of any changes in their financial situation, investment objectives, or account restrictions that could affect their financial standing. Our Firm takes actions on behalf of the client to hire or fire money managers used in the implementation of a client’s investment plan and execution of the Advisory Agreement with our Firm. Therefore, the firm has the discretionary authority to hire or fire the manager or to allocate assets among managers without obtaining the Client’s consent. WRAP FEE PROGRAM We do not participate in a Wrap Fee Program. ASSETS Fidelis Wealth Advisors, as of December 31, 2023 has $160,220,491 in discretionary reportable assets under man- agement and $32,718,754 in non-discretionary reportable assets under management for a total of $192,939,245 in assets under management. The firm also has assets under advisement of $747,455.