HOLOS INTEGRATED WEALTH

Holos Integrated Wealth Form ADV Part 2A Item 1. Brochure 224 East Street Road Office B2AB Kennett Square, PA 19348 Phone: (484) 893-4599 Email: dmatulewicz@holosiw.com Date: February 27, 2026 This Brochure (Part 2A of Form ADV) provides you with information about the qualifications, business practices and advisory services of Holos Integrated Wealth, LLC (the “Firm”). The Firm does business as “Holos Integrated Wealth” and is sometimes referred to herein by that name. The Firm is an investment adviser registered with the Securities and Exchange Commission. Registration does not imply a certain level of skill or training, only that we have filed registration documents in the appropriate jurisdictions and with the respective governmental entities. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Holos Integrated Wealth can be found on the Investment Adviser Public Disclosure website at adviserinfo.sec.gov by using our identification number referred to as a CRD number. The Firm’s CRD No. is 329884. If you have any questions about the content of this brochure, please contact us at the telephone number or email address shown above. 1  Holos Integrated Wealth Item 2. Material Changes This version of our Brochure dated February 27, 2026, is an annual updating amendment. Below is a Summary of Material Changes that have been updated in this Brochure since our last annual updating amendment dated March 18, 2025. 1. We have updated Items 4 and 5 to reflect that the Firm no longer offers financial planning as a standalone service. Please see Items 4 and 5 for more information. 2. Investment adviser representatives of the Firm are no longer independently licensed as insurance agents. Please see Item 10 for more information. If you would like another copy of this Brochure, please download it from the SEC website as indicated above or contact our Chief Compliance Officer, Brian Stephenson at (484)-893-4599 or via email at bstephenson@holosiw.com 2  Holos Integrated Wealth Table of Contents Item 3. Item 1. Form ADV Part 2A 1 Item 2. Material Changes 2 Item 3. Table of Contents 3 Item 4. Advisory Services 5 A. Types of Advisory Services: 5 B. Regulatory Assets Under Management 6 Item 5. Fees and Compensation 6 A. Fees and Compensation for Wealth Management Services 7 C. Other Fees, e.g. Other Types of Fees 7 E. Termination and Refunds 8 Item 6. Performance Based Fees and Side-By-Side Management 8 Item 7. Types of Clients 9 Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss 9 A. Methods of Analysis 9 B. Investment Strategies 9 C. Risks of Investing 10 Item 9. Disciplinary Information 15 Item 10. Other Financial Industry Activities and Affiliations 15 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 16 A. Proprietary Trading 17 B. Participation or Interest in Client Transactions 17 Item 12. Brokerage Practices 17 A. Selection and Recommendation 17 B. Research and Other Soft Dollar Benefits 17 C. Brokerage for Client Referrals 18 D. Directed Brokerage 18 E. Order Aggregation 18 Item 13. Review of Accounts 19 Item 14. Client Referrals and Other Compensation 19 Item 15. Custody 20 Item 16. Investment Discretion 20 Item 17. Voting Client Securities 20 3  Holos Integrated Wealth Item 18. Financial Information 20 4  Holos Integrated Wealth Advisory Services Item 4. Holos Integrated Wealth, LLC (referred to herein as “Holos Integrated Wealth,” “Holos,” “Firm,” “we,” and “our”) is an independent investment advisory firm that is registered with the U.S. Securities and Exchange Commission (“SEC”). The Firm was formed in 2015 as a limited liability company in Pennsylvania and is currently wholly owned by Dave Matulewicz and Brian Stephenson. Mr. Stephenson is the Firm’s Chief Compliance Officer. For more information about Mr. Matulewicz and Mr. Stephenson, please see their brochure supplements (Form ADV Part 2B). A. Types of Advisory Services: The Firm offers the following types of advisory services. 1. Wealth Management Wealth management services are provided on a discretionary basis. Clients will be asked to grant discretionary authority to the Firm by signing our Investment Advisory Agreement. “Discretionary authority” simply means we decide what securities to buy and sell for clients, and the time and price at which they are bought and sold, without seeking or obtaining the client’s approval of each transaction. Members of our investment team will meet with the client to develop an understanding of the client’s financial objectives and goals. We will also discuss concepts related to risk, as well as the client’s ability and willingness to take on risk in the client’s overall investment portfolio. We will ask the client questions designed to determine the appropriate investment horizon, risk profile, financial goals, income and other various items we deem necessary. Clients are given the ability to impose reasonable restrictions on their management of their investments, including specific investment selections and sectors. However, the Firm will not enter into an investment advisor relationship with a client whose investment objectives may be considered incompatible with the Firm’s investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. After we meet with a client, we will develop a portfolio customized to the specific needs of the client as we understand them based on our discussions with the client and review of the client questionnaire. Each client will be asked to open one or more trading account (“Account(s)”) at a “qualified custodian,” which is usually a securities broker-dealer, bank, or trust company (the “Custodian”). We will implement transactions on the client’s behalf and according to the client’s profile in the Account(s). This portfolio may comprise, among other things, stocks, bonds, preferred securities, publicly traded partnerships, ETFs, mutual funds, separately managed accounts, listed options on ETFs and stocks, cash or cash equivalents and select alternative investments. Unless otherwise agreed to, 5  Holos Integrated Wealth We will also monitor the client’s Account(s) to ensure that they are meeting the client’s investment objectives and other requirements. If any changes are needed to the client’s investments, We will either make the changes or recommend the changes to the client. These changes may involve selling a security or group of investments and/or buying others, or keeping the proceeds in cash or some liquid alternative. The client will receive written or electronic confirmations from the Custodian after any changes are made in the client’s Account(s). The client will also receive statements at least quarterly from the Custodian. Our Investment Advisory Agreement outlines the responsibilities of both the client and the Firm. 3. Retirement Plan Rollovers Sometimes we will recommend that a client “roll over” assets that are held in an existing tax-qualified retirement account, such as a 401(K), to be managed by us in an Individual Retirement Account (“IRA”) or other similar account. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan, and may engage in a combination of these options: (i) leave the money in the former employer’s plan, if permitted; (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted; (iii) roll over to an IRA, or (iv) cash out the account value. When we provide investment advice to clients regarding their 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. If we recommend that a client roll over their retirement assets into an account to be managed by us, such a recommendation creates a conflict of interest if we will earn an advisory fee on the rolled-over assets. We address this conflict of interest by ensuring any such recommendations are in the client’s best interest. No client is under any obligation to roll over retirement assets to an account to be managed by us. B. Regulatory Assets Under Management As of January 31, 2026, Holos Integrated Wealth manages approximately $233,097,307 in client assets. All assets are managed on a discretionary basis. Fees and Compensation Item 5. This Section provides information regarding the Firm’s fees and compensation for the services described in Item 4. Lower fees for comparable services may be available from other sources. The exact fees and other terms applicable to each client will be described in the Investment Advisory Agreement. 6  Holos Integrated Wealth A. Fees and Compensation for Wealth Management Services Holos Integrated Wealth charges fees to investment management clients based on a percentage of assets under management (“Advisory Fee”). The specific Advisory Fee charged by the Firm for its advisory services will be stated in each client’s Investment Advisory Agreement. Advisory Fees are negotiable, and not all clients of Holos’ clients will be charged the same fee or according to the same fee schedule. Unless otherwise agreed, the tiered Advisory Fees charged to the Account(s) are as follows: Account Assets On the first $500,000 On the next $500,000 On the next $2 million Over $3 million Advisory Fee 1.5% 1.25% 1.0% 0.85% Advisory Fees are billed monthly in advance and are calculated by multiplying one-twelfth of the annual Advisory Fee shown above by each Account’s prior month-end balance. Additionally, at the time of each monthly billing, the Firm will bill a pro-rata amount for new deposits (whether in cash or securities) based on the number of days remaining in the previous month at the time of deposit. This same proration method is used to bill for the first partial month of service. At the end of the advisory relationship, the Firm will refund a pro-rata amount of the last fee paid, representing the number of days remaining in the month after the termination date. Payment of Advisory Fees will be deducted from the client’s account(s) by the Custodian at our direction, as authorized by the Investment Advisory Agreement. The Custodian agrees to deliver an account statement, at least quarterly, directly to the client, showing all transactions in the account. The client is encouraged to review the statement(s) for the Account(s) for accuracy. The Firm will receive access to a duplicate copy of the statement that was delivered to the client. Our receipt of an asset-based fee presents a conflict of interest. This is because the more assets there are in the client’s account, the more the client will pay in fees. Therefore, we have an incentive to encourage clients to increase the assets in their accounts. We address this conflict of interest be ensuring any such recommendations are in the client’s best interest. B. Other Fees, e.g. Other Types of Fees Brokerage commissions, transaction charges, handling fees, custodial fees, service charges, ticket charges and other similar charges, if any, are not included in our fees and must generally be paid by the client. Clients will also typically pay, indirectly, charges imposed directly 7  Holos Integrated Wealth by the manager of a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus. Examples include fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, annuity fees, IRA and qualified retirement plan fees, and other fund expenses. Examples of other types of fees a client remains responsible to pay include mark-ups and mark-downs, spreads paid to market makers, wire transfer fees, ADR fees, overnight check fees, close-out fees, activity assessment fees and taxes on brokerage accounts and securities transactions. All clients will be delivered a current and accurate schedule of fees charged by the Custodian and are encouraged to carefully review those documents. Clients have a right to obtain current lists of such charges from the Custodian. Our Firm does not receive any portion of these fees. For more information regarding brokerage practices, see Item 12. Fidelity does not charge transaction fees for equity and exchange traded fund transactions in accounts that either receive electronic account statement delivery or have over $1 million in assets in their accounts held at Fidelity. A client who wishes to avoid transaction fees for those types of transactions but who do not have a balance of $1 million or more should choose electronic statement delivery at the time their account is opened, or, for current clients, contact Holos Integrated Wealth to change the delivery method. The Firm does not make any recommendations regarding whether a client should receive paper or electronic statements. D. Tax Preparation Reimbursement At the Firm’s sole discretion, the Firm may pay on the client’s behalf, or reimburse clients, in part or in whole, for fees or expenses paid by the client in connection with the preparation of the client’s tax documents. The issuance of the Tax Preparation Reimbursement is determined on a client-by-client basis. If we agree to reimburse these fees, we may charge a higher Advisory Fee sufficient to cover our costs of such reimbursement, plus reasonable compensation for administering the process. This practice is consistent with Holos’ policy that Advisory Fees are negotiable, and not all clients will be charged the same fee or according to the same fee schedule. E. Termination and Refunds Either party may terminate the Investment Advisory Agreement for our wealth management services in writing at any time. At the end of the advisory relationship, the Firm will refund a pro-rata amount of the last fee paid, representing the number of days remaining in the month after the termination date. Performance Based Fees and Side-By-Side Management Item 6. Performance-based fees are based on a share of capital gains on or capital appreciation of the client’s assets. Side-by-side management occurs when advisers manage both accounts that are charged a performance-based fee and accounts that are charged another type of fee, such as 8  Holos Integrated Wealth an hourly or flat fee or an asset-based fee. We do not accept performance-based fees, nor do we engage in side-by-side management. Types of Clients Item 7. The Firm provides investment advisory services to individuals, high net worth individuals, pension and profit sharing plans (but not the plan participants or government pension plans), trusts, estates, charitable organizations, and corporations or businesses not listed above. Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis The Firm uses the following methods of analysis in formulating and executing our investment strategy: • Macroeconomic Analysis: looking at long-term trends and relationships across wide sectors of the economy and financial markets. • Fundamental Analysis: researching the financial variables of the investment to identify whether or not it is a good value at the current price. • Cyclical Analysis: looking at historical relationships between various groupings of assets and how they are affected by the economic business cycle. • Technical Analysis: applying established “techniques” to the price history of an asset in order to identify potential future price movement based on historical patterns. Each client’s portfolio is evaluated on a periodic basis. Using our research and analysis and if we identify any better opportunities, we optimize the portfolio to coincide the client’s individual needs and our investment outlook. B. Investment Strategies The Firm constructs and implements long term, goals-based investment strategies for their clients. A given investors need, ability and willingness to assume market risk are the primary driving factors to high level asset allocation decisions. This assessment includes but is not limited to investment goals, risk profile, liquidity needs, client specific tax circumstances, special circumstances and generational planning. Some of the factors we use to evaluate equity investment opportunities include: • Business Opportunity: analyzing the main story driving the investment’s ability to grow and, ultimately, its return to shareholders. • Risk Factors: considering any potential news, events, or trends which may undermine the opportunity. • Current Financial Valuation: calculating how the company is valued by the market compared to its reported business performance relative to its peers. 9  Holos Integrated Wealth • Special Situations: short term events or trends that may indicate an opportunity to acquire an investment at a favorable price. • Competition: whether the company have competitors and/or how difficult its business is to replicate by new entrants to the industry. • Leadership: judging the temperament and ability of the management team. We base our analysis predominantly on publicly available research such as regulatory filings, press releases, competitor analysis, and in some cases research we receive from the Custodian or other outside sources. C. Risks of Investing There are always risks to investing. All clients should be aware that all investments are subject to the potential loss of principal that clients should be prepared to bear. Clients should discuss specific investment decisions with their investment professional. All investing involves risk and investments may lose value. Past performance is not indicative of future performance. It is impossible to describe all possible types of risks which may affect investments. Among the risks are the following: • Concentration Risk. To the extent a portfolio is concentrated in assets related to a particular industry or geographic region, the portfolio will be subject to additional volatility risks associated with such industry or region. In addition, concentrating in a single industry or group of industries may be more susceptible to any single economic, market, political or regulatory occurrence affecting that industry or group of industries. • Market Risk. Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations. • Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Interest Rate Risk. Movements in interest rates may directly cause prices of fixed income securities fluctuate. For example, rising interest rates can cause “high quality, relatively safe” fixed income investments to lose principal value. • Credit Risk. If debt obligations held by an account are downgraded by ratings agencies or go into default, or if management action, legislation or other government action 10  Holos Integrated Wealth reduces the ability of issuers to pay principal and interest when due, the value of those obligations may decline, and an account’s value may be reduced. Because the ability of an issuer of a lower-rated or unrated obligation (including particularly “junk” or “high yield” bonds) to pay principal and interest when due is typically less certain than for an issuer of a higher-rated obligation, lower rated and unrated obligations are generally more vulnerable than higher-rated obligations to default, to ratings downgrades, and to liquidity risk. • Purchasing Power Risk. Purchasing power risk is the risk that an investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. • Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. For example, Treasury Bills are highly liquid, while real estate properties are not. Some securities are highly liquid while others are highly illiquid. Illiquid investments carry more risk because it can be difficult to sell them. • Political Risk. Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world. • Regulatory/Legislative Developments Risk. Regulators and/or legislators may promulgate rules or pass legislation that places restrictions on, adds procedural hurdles to, affects the liquidity of, and/or alters the risks associated with certain investment transactions or the securities underlying such investment transactions. Such rules/legislation could adversely affect the value associated with such investment transactions or underlying securities. Future legal, tax and regulatory changes could occur that may adversely affect business and require additional reporting for registered investment advisors. The SEC, other regulators and self- regulatory organizations and exchanges have taken various extraordinary actions in connection with market events and may take additional actions. Registered investment advisers may also be adversely affected by changes in the enforcement or interpretation of existing laws, rules and regulations, including tax laws, by federal, state and non-U.S. agencies, courts, authorities or regulators. • Risks Related to Investment Term. If the client requires a liquidation of their portfolio during a period in which the price of the security is low, the client will not realize as much value as they would have had the investment had the opportunity to regain its value, as investments frequently do, or had it been able to be reinvested in another security. • Business Risk. Many investments contain interests in operating businesses. Business risks are risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a 11  Holos Integrated Wealth steady stream of customers who buy electricity no matter what the economic environment is like. • Financial Risk. Many investments contain interests in operating businesses. Excessive borrowing to finance a business’ operations decreases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of default risk. • Reinvestment Risk. This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Independent Manager Risk. If the Firm decides to select certain Independent Managers to manage a portion of its clients’ assets, we will continue to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, we do not have the ability to supervise the Independent Managers on a day-to-day basis. Finally, In certain instances, the agreement between the Firm and Independent Managers may limit the Independent Manager’s liability with respect to advice provided to the client’s Account(s)otherwise limit the client’s rights. • Price Deterioration for Non-Discretionary Clients. When the Firm makes a decision to invest in or sell out of a particular investment, the Firm will generally communicate to its non- discretionary clients and explain the recommendation. Transactions will be effected only for discretionary clients and those non-discretionary clients that have approved a purchase or sale. Non-discretionary clients who delay communicating their approval for a purchase or sale to the Firm will have their transaction executed later and possibly at a less favorable price than other clients, if the market conditions for the recommended security deteriorate. • Cybersecurity Risk. The Firm’s information and technology systems may be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by its professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. Although we have implemented various measures to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, we may have to make a significant investment to fix or replace them. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in our operations and result in a failure to maintain the security, confidentiality or privacy of sensitive data, including personal 12  Holos Integrated Wealth information relating to Client accounts. Such a failure could harm the Firm’s reputation or subject it or its affiliates to legal claims and otherwise affect their business and financial performance. Any failure of our information, technology or security systems could have an adverse impact on its ability to manage the client accounts referred to herein. technological developments, • Economic Conditions Risk. Changes in economic conditions, including, for example, interest rates, inflation rates, currency and exchange rates, industry conditions, competition, trade relationships, political and diplomatic events and trends, tax laws and innumerable other factors, can affect substantially and adversely the investment performance of a client’s account. Economic, political and financial conditions (including military conflicts and financial sanctions), or industry or economic trends and developments, may, from time to time, and for varying periods of time, cause volatility, illiquidity or other potentially adverse effects in the financial markets. Economic or political turmoil, a deterioration of diplomatic relations or a natural or man-made disaster in a region or country where the Firm’s clients’ assets are invested may result in adverse consequences to such clients’ portfolios. None of these conditions is or will be within the control of the Firm, and no assurances can be given that we will anticipate these developments. • Epidemic Risk. An epidemic outbreak and reactions to such an outbreak could cause uncertainty in markets and businesses, including the Firm’s business, and may adversely affect the performance of the global economy, including causing market volatility, market and business uncertainty and closures, supply chain and travel interruptions, the need for employees and vendors to work at external locations, and extensive medical absences. The Firm has policies and procedures to address known situations, but because a large epidemic may create significant market and business uncertainties and disruptions, not all events that could affect the Firm’s business and/or the markets can be determined and addressed in advance. • Custody Risk. The Firm is required to maintain certain client assets with a qualified custodian. Clients may incur a loss on securities and cash held in custody in the event of a custodian’s or sub-custodian’s insolvency, negligence, fraud, poor administration or inadequate recordkeeping. Generally, deposits maintained at a bank do not become part of a failed bank’s estate however, the Firm’s operations could be impacted by the bank’s insolvency in that there may be a delay in access to liquidity, trade settlement, delivery of securities, etc. Establishing multiple custodial relationships could mitigate custodial risk in the event of a bank failure. • Exposure to Material, Non-Public Information Risk. From time to time, The Firm’s employees receive material, non-public information with respect to an issuer of publicly traded securities resulting from professional and/or personal channels. In such circumstances, our clients may be prohibited, by law, and policies and procedures for a period of time from (i) unwinding a position in such issuer, (ii) establishing an initial position or taking any greater position in such issuer, and (iii) pursuing other investment opportunities related to such issuer. 13  Holos Integrated Wealth • Counterparty Risk. The Firm and/or its clients may be subject to credit and liquidity risk with respect to the counterparties. Exposure to credit and liquidity risk from counterparties can occur through a wide range of activities when dealing with, including but not limited to, service providers, banks, brokers, insurance providers, trading counterparties, or other entities. Should a counterparty become bankrupt or otherwise fail to perform its obligations under a contract due to financial difficulties, there may be significant delays in obtaining any or limited recovery under a contract in a bankruptcy court or other reorganization proceeding. The lack of any independent evaluation of such counterparties’ financial capabilities, and the absence of a regulated market to facilitate settlement or provide access to capital will increase the potential for losses by the Firm and/or clients especially during unusually adverse market conditions. THIS LIST OF RISK FACTORS DOES NOT PURPORT TO BE A COMPLETE ENUMERATION OR EXPLANATION OF THE RISKS INVOLVED IN CONNECTION WITH THE MANAGEMENT OF CLIENTS’ ACCOUNTS. IN ADDITION, PROSPECTIVE CLIENTS SHOULD BE AWARE THAT, AS THE MARKET DEVELOPS AND CHANGES OVER TIME, INVESTMENTS OF BEHALF OF CLIENTS’ ACCOUNTS MAY BE SUBJECT TO ADDITIONAL AND DIFFERENT RISKS. In addition, there is no assurance that a mutual fund, an ETF, or any security will achieve its investment objective. The principal risks of investing in any mutual fund or ETF are market risk, diversification risk and style risk. To the extent that a mutual fund or ETF invests in foreign securities or debt securities, a fund would be subject to foreign exposure risk, interest rate risk and credit risk. A fund may invest in derivative instruments that carry derivative instruments risk. A principal risk is the risk that the value of equity securities may decline. Although a mutual fund or ETF may be a diversified fund, it may invest in securities of a limited number of issuers to achieve a potentially greater investment return than a fund that invests in a larger number of issuers. As a result, price movements of a single issuer’s securities will have a greater impact on this fund’s net asset value causing it to fluctuate more than that of a more widely diversified fund. These and other risk considerations are discussed in a fund’s prospectus. Past performance of investments is no guarantee of future results. Mutual fund investing involves risk including the possible loss of principal. Non-diversified funds are more susceptible to financial, market and economic events affecting the particular issuers and industry sectors in which they invest and therefore may be more volatile or risky than less concentrated investments. There can be no assurance that any fund will be able to achieve its investment objective. For more information on a particular fund’s associated risks, please refer to that fund’s prospectus or equivalent disclosure document. Due to the volatile nature and risks involved when investing in certain types of strategies and/or securities, clients should be aware that the actual return and value of their account(s) may fluctuate and at any point in time be worth more or less than the amount originally invested. We do not represent, guarantee or imply that the services or methods of analysis employed by 14  Holos Integrated Wealth the Firm can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. Disciplinary Information Item 9. Holos Integrated Wealth is required to disclose the facts of any legal or disciplinary events that are material to a client’s evaluation of our advisory business or the integrity of our management. We do not have any required disclosures to report in response to this Item. Item 10. Other Financial Industry Activities and Affiliations Holos Integrated Wealth does not have a related person that is: • A broker/dealer, municipal securities dealer or government securities dealer or broker • An investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) • An investment adviser or financial planner • A futures commission merchant, commodity pool operator or commodity trading advisor • A banking or thrift institution • An accountant or accounting firm • A lawyer or law firm • An insurance company or agency • A pension consultant • A real estate broker or dealer • A sponsor or syndicator of limited partnerships Holos investment adviser representatives are not registered to conduct business as investment adviser registered representatives of any broker-dealer. As such, Holos representatives are prohibited from receiving transaction-based compensation for the sale of securities products. The Firm, then known as “Black Stone Partners, LLC (“Black Stone”), entered into an Asset Purchase Agreement on July 18, 2022 with Janet Rzewnicki, a Delaware professional association, and Janet Rzewnicki, an individual (collectively, “Rzewnicki”). Under the terms of the Asset 15  Holos Integrated Wealth Purchase Agreement, Black Stone purchased the rights in and to client accounts, relationships, and contracts. Payment for these purchased rights will continue monthly for 60 months following the effective date of the Asset Purchase Agreement. Rzewnicki may provide tax preparation and other accounting services to Holos’ clients. Holos compensates Rzewnicki under the terms of the Asset Purchase Agreement. Please see Item 14 for more information about our relationship with Rzewnicki. The Firm, then known as “Black Stone Partners, LLC (“Black Stone”), entered into an Asset Purchase Agreement on December 1, 2019 with David P. Griffith, P.A., a Delaware professional association, and David P. Griffith, an individual (collectively, “Griffith”). Under the terms of the Asset Purchase Agreement, Black Stone purchased the rights in and to client accounts, relationships, and contracts. Payment for these purchased rights will continue monthly for 60 months following the effective date of the Asset Purchase Agreement. Griffith may provide tax preparation and other accounting services to Holos’ clients. Holos compensates Griffith under the terms of the Asset Purchase Agreement. Please see Item 14 for more information about our relationship with Griffith. Notwithstanding any of the above, in connection with the Tax Preparation Reimbursement, Holos is not compensated, directly or indirectly, by any accountant or entity for referring any clients and no reciprocal referral arrangement exists between Holos and any accountants. Additionally, no accountants provide other services to the Firm in connection with these referral arrangements. While the Firm may have incentive to refer clients to an accountant, and the accountant may have incentive to refer clients to the Firm, this incentive is limited to a mutual appreciation for each operation’s respective success in the marketplace. As discussed below, Holos Integrated Wealth has in place a Code of Ethics that provides for Holos and its investment adviser representatives to exercise its fiduciary duty to clients to act in the best interest of the clients and always place the client’s interests first and foremost. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Holos Integrated Wealth, its management and supervised persons (collectively “personnel”), subscribe to a strict Code of Ethics. The Code of Ethics is designed to comply with the investment advisory laws and regulations that require firms to act as fiduciaries in transactions with their clients. The Firm’s inherent fiduciary duty requires that the Firm act solely in its clients’ best interest and adhere to standards of utmost integrity in its communications and transactions. These standards ensure that clients’ interests are preeminent. Accordingly, the Firm has implemented extensive policies, guidelines, and procedures that promote ethical practices and conduct by all of the Firm’s personnel. The Firm’s Code of Ethics specifies and prohibits certain types of transactions deemed to create conflicts of interest (or perceived conflicts of interest), as well as establishes reporting requirements and enforcement procedures relating to personal transactions by its personnel. The Code of Ethics specifically deals with professional standards, insider trading, personal trading, gifts and 16  Holos Integrated Wealth entertainment, and fiduciary duties. The Code establishes the Firm’s ideals for ethical conduct based upon fundamental principles of openness, integrity, honesty, and trust. The Firm will provide a copy of the complete Code of Ethics to any client or prospective client upon request. A. Proprietary Trading The Firm and its representatives are permitted to buy or sell securities for their own accounts that the Firm also recommends to clients, consistent with the Firm’s policies and procedures. This presents a conflict of interest because it may be possible for us or our representatives to receive more favorable prices than our clients. We will always document any transactions that could be construed as a conflict of interest. To mitigate this conflict of interest, we have adopted trading procedures designed to assure that neither we nor our representatives obtain favorable prices. We will also monitor trading reports for adherence to our Code of Ethics. B. Participation or Interest in Client Transactions The Firm does not recommend that clients buy or sell securities in which it or a related person may have a material financial interest. Item 12. Brokerage Practices A. Selection and Recommendation Holos Integrated Wealth recommends that clients utilize the brokerage and clearing services of Fidelity Brokerage Services, LLC (“Fidelity”) or Charles Schwab & Co., Inc. (“Schwab”). Factors which the Firm considers in recommending Fidelity, Schwab, or any other broker-dealer to clients include their respective financial strength, breadth of service, existing relationships, execution, pricing, research and resources available. Not all investment advisers recommend that a client use a particular broker-dealer. B. Research and Other Soft Dollar Benefits The Firm receives research or other products or services (i.e., soft dollar benefits) from broker-dealers in exchange for placing trades or processing securities related transactions for clients. We do not have to pay the broker-dealer for these services and no client is charged for these services. Therefore, we receive a benefit. The products or services received may benefit all of our customers, not just those whose assets are custodied at the broker-dealer who provides the products or services. This may result in higher transaction costs than those that would have been incurred but for the soft dollar benefits. This is a conflict of interest, as we have an incentive to recommend Fidelity or Schwab because of our existing relationship and the benefits we receive. We mitigate this conflict by conducting best execution reviews and through application of our policies and procedures. As part of negotiating its custodial relationship with Fidelity, the Firm was informed it is required to maintain a minimum of $25 million in assets on the Fidelity platform or else additional platform fees may be charged to the Firm. This platform fee is waived during the first 12 months 17  Holos Integrated Wealth of the Firm’s relationship with Fidelity. Additionally, Fidelity will periodically review the relationship in light of the revenue derived from the relationship with the Firm. In Fidelity’s discretion, Fidelity may choose to end the custodial relationship or impose increased costs and fees on the Firm. As a result, the Firm has an incentive to recommend its clients maintain in an aggregate of at least $25 million through the Fidelity platform. Additionally, to maintain current pricing, the Firm is further incentivized to maintain or increase the revenue paid to Fidelity as a result of the arrangement. As part of this incentive, the Firm may recommend that a client’s cash, or a portion of their available cash, be held in a cash vehicle that is advantageous to Fidelity, including proprietary products developed by Fidelity, or affiliates of Fidelity. These incentives represent conflicts of interest. The Firm mitigates this conflict by conducting best execution reviews and ensuring each recommendation is in the best interest of the client. Additionally, receipt of lower custodial pricing benefits all of Holos’ clients who use Fidelity, in that lower custodial pricing allow Holos to keep its Advisory Fees lower than it would be if custodial pricing were higher. Holos Integrated Wealth clients do not pay more for investment transactions effected and/or assets maintained as a result of the above arrangements. There is no corresponding commitment made by the Firm to any entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other investment products as a result of the above arrangements. Nevertheless, receipt of the benefits described in this section from Fidelity and Schwab creates a conflict of interest in that we have an incentive to recommend them based on receipt of the benefits rather than client’s interest in receiving the most favorable execution. The Firm manages that conflict of interest by conducting a best execution analysis to assure that the total costs to the client is reasonable in relation to the value of the services provided. C. Brokerage for Client Referrals The Firm does not receive client referrals or compensation of any kind from broker- dealers or other third parties in exchange for using any particular broker-dealer. D. Directed Brokerage We routinely recommend that the client direct our Firm to execute transactions through broker-dealers with which we have a business relationship. As such, we may be unable to achieve the most favorable execution of the client’s transactions and the client may pay higher brokerage commissions than the client might otherwise pay through another broker-dealer that offers the same types of services. However, we do not permit clients to use our services through the use of custodians with which We have no relationship. E. Order Aggregation We may enter trades as a block where possible and when advantageous to clients whose accounts have a need to buy or sell shares of the same security. If a block trade occurs, the impacted clients typically will receive a price that represents the average of the prices at which all of the transactions in the block were executed. This blocking of trades permits the trading of aggregate blocks of securities from multiple client accounts, and allocation on a pro-rata basis 18  Holos Integrated Wealth between all accounts included in any such block. If average-price allocation is unavailable, we will apply another mechanism to assume equitable treatment of those participating in the block trade. Block trades may include employee transactions. Block trading allows the Firm to execute equity trades in a timelier, equitable manner, and may reduce overall costs to clients. Item 13. Review of Accounts Client account values are marked-to-market daily and portfolios are reviewed for performance, risk, and asset allocation once per calendar month by an investment adviser representative of Holos. Special market or news events may trigger extra or more frequent reviews in between the normal schedule. We review accounts on at least an annual basis for our Wealth Management clients. The nature of these reviews is to determine whether the Account(s) are in line with their investment objectives, and are appropriately positioned based on market conditions, and investment policies, if applicable. We attempt to understand anything that may have changed in our client’s personal, professional, or financial situations. Clients are advised that they should notify Holos promptly of any changes to the client’s financial goals, objectives or financial situation as such changes may require Holos to review the client’s portfolio and make recommendations for changes. We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Financial Planning or Consulting clients will receive reviews of their written plans at their request. Clients will be provided with written account statements reflecting the transactions occurring in the client’s account at least on a quarterly basis, direct from the account Custodian. Clients will be provided with confirmations for each securities transaction executed in the client’s Account(s)direct from the account Custodian. Item 14. Client Referrals and Other Compensation This research and these tools may be considered a material economic benefit and is described above in Item 12 Brokerage Practices. Holos Integrated Wealth has entered into agreements with Rzewnicki and Griffith under which Rzewnicki and Griffith may refer potential clients to us. This creates a conflict of interest because we compensate them with a recurring referral fee based on the fees collected by Holos. This referral fee is paid by Holos and is not passed on to the client. We never charge a client more as a result of such referrals, and we always act in the best interest of our clients pursuant to our 19  Holos Integrated Wealth fiduciary duties. If you were referred to Holos, you will receive specific disclosures regarding the compensation arrangement between Holos and Rzewnicki or Griffith. Item 15. Custody The Firm has custody of client funds and securities because of our ability to deduct Holos’ fees from clients’ accounts that are authorized in the Investment Advisory Agreement between clients and Holos. We also have custody due to our standing authority to make third-party transfers on behalf of our clients who have granted us this authority. This authority is granted to us by the client through the use of a standing letter of authorization (“LOA”) established by the client with his or her qualified custodian. The standing LOA authorizes our Firm to disburse funds to one or more third parties specifically designated by the client pursuant to the terms of the LOA and can be changed or revoked by the client at any time. We have implemented the safeguard requirements of SEC regulations by requiring safekeeping of your funds and securities by a qualified custodian. We have further implemented procedures to comply with the requirements outlined by the SEC in its February 21, 2017 No-Action Letter to the Investment Adviser Association. Accounts are custodied at the Custodian, which is a “qualified custodians” as that term is defined in Rule 206(4)-2(d)(6) of the Investment Advisers Act of 1940. Clients will receive account statements directly from these custodians and should carefully read the statements for accuracy. Investment Discretion Item 16. Clients provide the Firm with investment discretion on their behalf, pursuant to the Investment Advisory Agreement. By granting investment discretion, Holos Integrated Wealth is authorized to execute securities transactions, determine which securities are bought and sold, and the total amount to be bought and sold. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with Holos’ written acknowledgement. Item 17. Voting Client Securities The Firm does not vote proxies on client securities on behalf of its clients. We may express an opinion for a specific proxy vote but clients are responsible for making elections relative to election of directors, mergers, acquisitions, tender offers, bankruptcy proceedings and other type events pertaining to the securities in their accounts. Clients receive proxies directly from the issuer or the custodian. Item 18. Financial Information The Firm does not require or solicit the prepayment of more than $1,200 in fees, six (6) months or more in advance, and therefore is not required to include a balance sheet with this Brochure. We do not have a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients and we have not been the subject of a bankruptcy petition at any time during the past ten years. 20  Holos Integrated Wealth 21