NOVEM GROUP

Form ADV Part 2A – Firm Brochure Novem Group CRD #158964 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 585-348-9525 www.novemgroup.com Updated: 11/10/2025 This document provides information about Novem Group. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you have any questions on the contents of this document. Novem Group, is an SEC- Registered Investment Adviser and is notice-filed in the following states: AZ, CA, CO, CT, DC, FL, GA, IA, IL, KS, LA, MA, MD, ME, MI, NC, ND, NE, NH, NJ, NY, OH, OR, PA, RI, SC, TN, TX, UT, VA, VT, WA. Additional information on Novem Group is available on the SEC’s website at www.adviserinfo.sec.gov. The information in this brochure has not been approved or verified by the SEC or by any state securities authority. 1  Item 2: Material Changes Novem Group would like to report the following changes to this document since the firm’s most recent ADV amendment filed on 3/24/2025: E. Assets Under Management As of 1/1/2025, Novem Group has the following assets under management: Total Discretionary $1,168,503,563 Total Non-Discretionary $245,138,005 Total Assets Under Management $1,413,641,568 2  Item 3: Table of Contents 1 2 3 4 Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business A. Firm Description B. Types of Advisory Services C. Client Tailored Services and Client Imposed Restrictions D. Wrap Fee Programs E. Assets Under Management Item 5: Fees and Compensation 5 A. Fee Schedule and Types of Fees B. Payment of Fees C. Clients are Responsible for Third Party Fees D. Prepayment of Fees E. Outside Compensation for the Sale of Securities to Clients a. Conflicts of Interest b. Advisory Fees in Addition to Commissions/Markups Item 6: Performance-Based Fees and Side-by-Side Management Item 7: Types of Clients Item 8: Methods of Analysis and Investment Strategies 6 7 7 A. Methods of Analysis B. Investment Strategies Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations 7 7 A. Registration as a Broker-Dealer or a Broker-Dealer Representative or Dual-Affiliation as an Investment Adviser Representative B. Registration Relationships Material to this Advisory Business C. Selection of Other Advisers or Managers Item 11: Code of Ethics, Participation/Interest in Client Transactions, Personal Trading 8 Investing Personal Money in the Same Securities as Clients A. Code of Ethics B. Recommendations Involving Material Financial Interests C. Item 12: Brokerage Practices 8 Investment Discretion A. Factors Used to Select Custodians B. Research and Soft-Dollar Benefits C. Block Trading D. Item 13: Review of Accounts 9 A. Frequency and Nature of Periodic Reviews B. Factors that will Trigger a Non-Periodic Review C. Regular Reports to Clients Item 14: Client Referrals and Other Compensation 9 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients B. Compensation to Solicitors for Client Referrals Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information 10 10 10 10 A. Balance Sheet and Financial Conditions 3  Item 4: Advisory Business A. Firm Description Novem Group is organized as a corporation in the state of New York. The date of its inception is August of 2011, and the principal owner is Robert J. Bartolotta. B. Types of Advisory Services Novem Group offers the following services to its advisory clients: Investment Supervisory Services Includes ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Novem Group’s Investment Policy Statement within the client contract outlines the client’s current situation and allows the representative to construct a plan to aid in the selection of a portfolio to correspond with that client’s risk tolerance, time horizon, and investment objectives. Additional services include, but are not limited to, determining risk tolerance, developing investment strategies and asset allocations, and regular monitoring of accounts and portfolios. The current investments of each client are evaluated with respect to the client’s risk tolerance, investment time horizon, and other information related to suitability. Discretionary authority may be requested from clients in order to select securities and execute transactions without permission from the client beforehand. Representatives use tools and programs to determine a client’s risk tolerance and to run investment proposals. Financial Planning Financial planning may include, but is not limited to, investment planning, retirement planning, college planning, debt and credit planning, discussing tax concerns, and evaluating life insurance and assets outside of the management of the representative. The services and fee structures, if applicable, are outlined in Novem Group’s Advisory Services Agreement. Available fee structures include a flat fee (dollar amount or percentage of assets), an hourly rate, or a tiered fee schedule with a floating flat rate percentage based on an account/portfolio value. Selection of Other Advisers Novem Group may direct clients to third party money managers. This relationship will be disclosed in the contract between Novem Group and the third party. Novem Group will be compensated via a fee share from the manager to which it directs clients. The fees shared will not exceed any limit imposed by any regulatory agency. Before selecting other advisers for clients, Novem Group will ensure the other adviser is properly licensed or registered. Services Limited to Specific Types of Investments Novem Group limits its investment advice and money management to mutual funds, ETFs, equities, bonds, fixed income, debt securities, options, REITs, and insurance products including annuities. Novem Group may use other securities to help diversify a portfolio. 4  C. Client Tailored Services and Client Imposed Restrictions Novem Group offers the same services to all its clients; however, specific client financial plans and their implementation are dependent upon the client’s contract. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs; however, if the restrictions prevent Novem Group or its representatives from properly servicing the account, or if the restrictions require Novem Group to deviate from its standard services, Novem Group reserves the right to end the relationship. D. Wrap Fee Program A wrap fee program is an investment program where the investor pays one stated fee that includes all management fees, transaction costs, fund expenses, and any other administrative fees. Novem Group sponsors a wrap fee program and offers both non-wrap and wrap portfolio management. The maximum total fee schedule is listed in Item 5.A. Clients who participate in the wrap fee program will not have to pay for transaction or trading fees of the custodian; however, clients are still responsible for all other fees. Compensation of Client Participation Other than advisory fees, Novem Group nor its representatives receive any additional compensation for the participant of clients in the wrap fee program. Compensation received may be more than what would have been received if the client paid separately for investment advice and other services; therefore, Novem Group and its representatives may have a financial incentive to recommend a wrap fee program. This relationship is reviewed periodically by the representative and the firm for suitability. E. Assets Under Management As of 1/1/2025, Novem Group has the following assets under management: Total Discretionary $1,168,503,563 Total Non-Discretionary $245,138,005 Total Assets Under Management $1,413,641,568 Item 5: Fees and Compensation A. Fee Schedule and Types of Fees Maximum Fee Schedule Total Assets Under Management Up to $250,000 $250,001 - $500,000 $500,001 - $1,000,000 $1,000,001 - $5,000,000 Over $5,000,0001 Maximum Annual Fee 2.50% 2.25% 2.00% 1.75% 1.50% These fees are negotiable depending upon the needs of the client and complexity of the situation, and the actual fee is indicated in the client’s contract. Fees are paid quarterly in advance or in arrears, and clients may terminate their contracts with written notice at any time. Refunds are given on a pro-rated basis if possible and are based on the number of days remaining in a quarter at the point of termination. This may not be possible with outgoing transfers and will be reviewed on a case-by-case basis. 5  A client may terminate their contract, without penalty and for a full refund, within 5 business days of signing the contract. Types of Fees Available fee structures for financial planning include a flat fee (dollar amount or percentage of assets), an hourly rate, or a tiered fee schedule with a floating flat rate percentage based on an account/portfolio value. The type of fee structure depends upon the complexity of the situation and the needs of the client. B. Payment of Fees Advisory fees are withdrawn directly from the client’s account or invoiced to the client with client written authorization found in the client’s contract. Fees are paid quarterly in advance or in arrears. C. Clients are Responsible for Third Party Fees Clients are responsible for the payment of all third-party fees (e.g., custodial/vendor fees, brokerage fees, mutual funds fee, transaction fees, etc.). These fees are separate and distinct from the fees charged by Novem Group and its representatives. D. Prepayment of Fees Novem Group collects fees in advance or in arrears. Fees that were collected in advance will be refunded based on the prorated amount of work completed at the point of termination and/or the total days left in the billing period once the contract has been terminated. Any fee owed to the client will be returned to the client by check or deposited in an active investment account, depending on how the original fee was collected and if it is determined to be possible. E. Outside Compensation for the Sale of Securities to Clients a. Conflict of Interest Novem Group and its representatives will accept compensation for the sale of securities or other investment products, including asset-based sales charges or services fees from the sale of funds to its clients. This presents a conflict of interest and gives the representative and Novem Group an incentive to recommend products based on the compensation received. When recommending the sale of securities or products for which Novem Group or its representatives receive compensation, the representative will document the conflict of interest in the client file and inform the client. Novem Group and its representatives have a fiduciary duty to keep the client’s best interest in mind. b. Advisory Fees in Addition to Commissions/Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. Item 6: Performance-Based Fees and Side-by-Side Management Novem Group does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation on the assets of a client. 6  Item 7: Types of Clients Novem Group provides investment advice and/or supervisory services to the following types of clients: Individuals Pension plans and profit-sharing plans Charitable organizations State or municipal government entities - - High net worth individuals - - - - Other Investment Advisers Item 8: Methods of Analysis and Investment Strategies A. Methods of Analysis Fundamental analysis - Involves the analysis of a company’s financial statements, financial health, and/or the analysis of management or competitive advantages, etc. to attempt to determine a company’s value and expected future earnings. This strategy may encourage trading in stocks that are undervalued. The risk assumed is that the market will fail to reach the expectation of the stock’s perceived value. Cyclical analysis - Involves the analysis of business cycles to attempt to determine favorable conditions for buying/selling a security. It assumes the markets react in cyclical patterns which, once identified, can be leveraged to provide positive performance. The risks associated with this strategy include that the markets do not always repeat cyclical patterns and if too many investors begin to implement it, the cycles may change. Technical analysis - Involves the analysis of statistics generated by market activity to identify patterns. Technical analysts do not attempt to measure a security’s intrinsic value, but instead use charts and other tools to identify the patterns to suggest future activity. The risks associated with this strategy include that if investors begin to use similar tools and follow the same concepts, it may lead to the prices moving in the predicted direction. Investment Strategies B. Novem Group and its representatives use long-term trading, short-term trading, and options trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Long-term trading is designed to capture market rates of both return and risk. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs. Short- term trading and options trading generally hold greater risk than long-term trading. Item 9: Disciplinary Information Novem Group does not have any criminal or civil actions, administrative proceedings, or self-regulatory organization proceedings to report. Please refer to your representative’s Novem Group ADV Part 2B Individual Disclosure Brochure, the FINRA BrokerCheck website, and the SEC IAPD website for more information. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker-Dealer or a Broker-Dealer Representative or Dual-Affiliation as an Investment Adviser Representative Investment Adviser Representatives of Novem Group may also be Registered Representatives of Osaic Wealth, Inc. and/or Investment Adviser Representatives of Osaic Advisory Services, LLC. 7  Please refer to your representative’s Novem Group ADV Part 2B Individual Disclosure Brochure, the FINRA BrokerCheck website, and the SEC IAPD website for more information. B. Registration Relationships Material to this Advisory Business Investment Adviser Representatives of Novem Group may also be Registered Representatives of Osaic Wealth, Inc., Investment Adviser Representatives of Osaic Advisory Services, LLC, and/or licensed insurance agents. From time to time, they will offer clients advice or products from these activities. Clients should be aware that these services pay a commission and may involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a Registered Investment Adviser. Novem Group and its representatives always act in the best interest of the client. Clients are in no way required to utilize the services of a representative of Novem Group in their outside capacities or outside business activities. Please refer to your representative’s Novem Group ADV Part 2B Individual Disclosure Brochure, the FINRA BrokerCheck website, and the SEC IAPD website for more information. C. Selection of Other Advisers or Managers Novem Group may direct clients to third party money managers and this relationship will be disclosed in the contract between Novem Group and the third party. Novem Group will be compensated via a fee share from the manager to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. These fees are negotiable depending upon the needs of the client and the complexity of the situation. Fees are paid quarterly in advance or in arrears, and clients may terminate their contracts with written notice at any time. Item 11: Code of Ethics, Participation/Interest in Client Transactions, Personal Trading A. Code of Ethics Novem Group has a written Code of Ethics, which is available upon request. B. Recommendations Involving Material Financial Interests Novem Group does not recommend that clients buy or sell any security in which a related person to Novem Group or that Novem Group has a material financial interest in. Investing Personal Money in the Same Securities as Clients C. From time to time, representatives of Novem Group may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity to buy or sell the same securities before or after recommending them to clients, which may result in a profit from the recommendation provided to the client. Such transactions create a conflict of interest. Novem Group will document any transaction that may be construed as a conflict of interest and will ensure client business is transacted before the representative’s business when the same securities are being bought or sold. Item 12: Brokerage Practices A. Factors Used to Select Custodians The following factors are used when Novem Group selects a custodian: Capability to execute, clear, and settle trades or to facilitate this service Capability to facilitate timely transfers and payments to and from accounts Capability to assist with back-office functions, recordkeeping, and client reporting Availability of investment research and tools to assist in making investment decisions - - - - - Quality of service - Competitiveness of the price of services and willingness to negotiate the price 8  Reputation, financial strength, and stability Availability of educational conferences and events Consulting on technology, compliance, legal, and practice management - - - B. Research and Soft-Dollar Benefits Novem Group does not currently receive any soft-dollar benefits. Novem Group receives no referrals from a broker/dealer or other third party in exchange for using that broker/dealer or third party. Novem Group will not allow clients to direct Novem Group to use a specific broker/dealer to execute transactions. Clients must use the custodian recommended by Novem Group and its representatives. C. Block Trading Novem Group maintains the ability to block trade across accounts. Block trading may benefit a large group of clients by providing Novem Group with the ability to purchase larger blocks, which may result in a lower transaction cost to the client. Investment Discretion D. Novem Group has discretionary authority to determine securities and the dollar amount of securities to be bought or sold in a client’s account. This is indicated in the client’s contract. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews Accounts are reviewed at least semi-annually by Robert J. Bartolotta, Chief Executive Officer of Novem Group, with regard to the information indicated on the Investment Advisory Contract. Transactions are captured both by Schwab and Transaction Review Preparation (TR Prep or TRP), a platform of Osaic Wealth, Inc., and reviewed daily by the Investment Adviser Representative’s Principal. If unavailable, client statements are reviewed. B. Factors that will Trigger a Non-Periodic Review Non-periodic reviews may be triggered by material market, economic, or political events, or by changes in the client’s financial situation, such as retirement, termination of employment, inheritance, etc. C. Regular Reports to Clients Each client will receive a report at least quarterly from the custodian. This report details the client’s account(s), including assets held, asset value, and transaction history. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients Novem Group receives an economic benefit from Schwab in the form of the support products and services it makes available to Novem Group and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which Novem Group would otherwise have to pay, including reimbursing termination fees when certain clients transfer assets to Schwab. Novem Group clients do not pay more for assets maintained at Schwab as a result of these arrangements. However, Novem Group benefits from the arrangement because the cost of these services would otherwise be borne directly by Novem Group. Clients should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit Novem Group, and the related conflicts of interest are described 9  above see Item 12— Brokerage Practices. B. Compensation to Solicitors for Client Referrals Novem Group compensates other Investment Adviser Representatives for client referrals and a Solicitor’s Agreement will be provided when this occurs. Novem Group requires clients to sign the Notification of Solicitor’s Agreement form to acknowledge receipt of the agreement in place. Item 15: Custody Novem Group, with client written authority, has limited custody of client’s assets through direct fee deduction of fees only. If the client chooses to be billed directly to the custodian, Novem Group would have constructive custody over that account and will have written authority from the client to do so. Clients will receive account statements, which should be carefully reviewed for completeness and accuracy. Item 16: Investment Discretion For the client accounts where Novem Group provides ongoing supervision, the client has given Novem Group written discretionary authority over the accounts with respect to the securities to be bought or sold and the dollar amount of securities to be bought or sold. The details of this relationship are fully disclosed to the client before any advisory relationship has begun and this is indicated in the client’s contract. Item 17: Voting Client Securities Novem Group will not ask for, nor accept, voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet and Financial Conditions Novem Group does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Neither Novem Group nor any of its management have any financial conditions that may reasonably impair the ability to meet contractual commitments to its clients. Novem Group has not been the subject of a bankruptcy petition in the last ten years. 10