Innovator is a Delaware limited liability company with its principal office and place of business located at 109 North Hale Street, Wheaton, Illinois 60187. Innovator has been registered with the SEC as an investment adviser since March 2017. H. Bruce Bond and John Southard, Jr. are the principal owners of Innovator. Innovator serves as investment adviser to each series of the Innovator ETFs Trust (the "Trust," each such series thereunder a “Fund,” and collectively the “Funds”). The Trust is organized under Delaware law as a Delaware statutory trust and is registered with the SEC under the Investment Company Act of 1940 (the “1940 Act”) as an open-end management investment company. Innovator also provides non-discretionary Model Portfolios to third-party advisers and/or to third-party platform providers. Adviser to the Trust Innovator acts as investment adviser to the Funds pursuant to an investment advisory agreement between the Trust and the Adviser with respect to the Funds (“Advisory Agreement”). Pursuant to the Advisory Agreement, Innovator is responsible for the day-to-day management of the Funds. The shares of the Trust are registered under the Securities Act of 1933, as amended (the “1933 Act”). Each Fund is an exchange-traded fund (“ETF”), meaning the Funds’ shares are listed on a national securities exchange, such as the Cboe BZX Exchange, Inc. or NYSE Arca, Inc., and trade at market prices. The Funds are subject to the general supervision of the Board of Trustees of the Trust (the “Board”). Pursuant to a supervision and administration services agreement between Innovator and the Trust, with respect to each Fund (“Supervision Agreement”), and subject to the general supervision of the Board, Innovator also provides or causes to be furnished, all management, supervisory and other services reasonably necessary for the operation of each Fund and bears the costs of various third-party services including, sub-advisory, fund administration, certain custody, audit, legal, transfer agency, and printing costs. The Supervision Agreement also requires Innovator to provide investment advisory services to the Funds pursuant to the Advisory Agreement. Innovator works with sub-advisers to facilitate portfolio management of the Funds. As compensation for the sub-advisory services provided to the Funds, Innovator pays to the applicable sub- adviser, a sub- advisory fee based upon a percentage of that Fund’s daily net assets. The level of the sub- advisory fee paid with respect to a Fund is negotiated between the Adviser and the applicable sub-adviser and will vary, depending on, among other things, the types of assets in which the Fund invests. Sub- advisory fees are generally accrued daily and are paid monthly in arrears. Additional information regarding the services provided by Innovator to the Trust can be found in the Funds’ prospectuses and statement of additional information, which are publicly available at www.innovatoretfs.com, on the SEC’s EDGAR Database available at www.sec.gov, by contacting the Funds’ principal underwriter, Foreside Fund Services, LLC at Three Canal Plaza, Suite 100, Portland, ME 04101, or by calling (800) 208-5212. ETF Model Program Innovator constructs and maintains non-discretionary model securities portfolios (“Model Portfolios”) to make asset allocation solutions available generally consisting of the Funds and/or other ETFs (the “ETF Model Program”). In the ETF Model Program, Innovator provides Model Portfolios either directly to third- party registered investment advisers and other financial intermediaries

(“Third-Party Advisers”) or indirectly to Third-Party Advisers through arrangements with third-party model portfolio platform sponsors (“Model Platform Sponsors”). Innovator monitors and updates each Model Portfolio on a periodic basis, generally annually, and delivers updates to the Third-Party Advisers and the Model Platform Sponsors, as appropriate. Certain Model Portfolios include allocations to third-party ETFs representing various other asset classes to complete allocations for certain Model Portfolios where the Trust does not offer a Fund providing exposure to the desired asset class. Under the ETF Model Program, Innovator does not have an advisory relationship with ETF Model Program subscribers and does not invest Third-Party Adviser assets or their underlying client assets. Third-Party Advisers subscribing to the Model Portfolios retain discretionary investment authority, trading authority, brokerage discretion for their client portfolios, and are responsible for determining the suitability of the Model Portfolios for their clients. If requested, Innovator may review the portfolios of institutional investors to offer analysis and consider how their portfolios could be further optimized via the inclusion of one or more of the Funds. These services are conducted in an effort to further facilitate the marketing and distribution of the Funds. The Adviser does not charge any fees in connection with the portfolio reviews and does not enter into an investment advisory agreement with any institutional investors regarding the portfolio reviews. Innovator makes the Model Portfolios available to Third-Party Advisers as an informational resource. The Model Portfolios are rebalanced on a pre-determined schedule. Third-Party Advisers, not Innovator, are responsible for selecting the investments for their underlying client accounts, including recommending, selecting, and managing their underlying client’s investment strategy. The Third-Party Adviser remains responsible for making investment decisions for their underlying client, including taking into account the underlying clients’ specific investment objectives, risk tolerances and financial circumstances. In certain arrangements, the Third-Party Adviser is an affiliate of the Model Platform Sponsor. Under the ETF Model Program, Innovator provides updates to the allocations in each Model Portfolio on an annual basis. To the extent a Third-Party Adviser or their underlying client determines to rebalance based on a Model Portfolio asset allocation change, tax consequences and transaction costs may be incurred. Innovator does not have and will not have, trading authority over any account of a Third-Party Adviser, including their underlying client accounts, based on a Model Portfolio. Any trading affected by a Third-Party Adviser or their underlying client may incur tax consequences, commissions, and other costs, which should be assessed by the Third-Party Adviser prior to pursuing the asset allocation change. Third- Party Advisers may use multiple strategies, including strategies of other investment managers. The implementation of any such investment strategy for an underlying client of a Third-Party Adviser, including one based on a Model Portfolio, will be conducted by the applicable Third-Party Adviser, who is responsible for making their own independent judgment as to how to incorporate any Model Portfolio information for any underlying client of such Third-Party Adviser. Regulatory Assets Under Management As of December 31, 2023, Innovator had approximately $17,432,817,984 in regulatory assets under management on a discretionary basis.