Victory Capital Holdings, Inc.

Section 16(a) of the Exchange Act and regulations of the SEC require our directors, executive officers and, with certain exceptions, persons who own more than 10% of a registered class of our equity securities, as well as certain affiliates of such persons, to file with the SEC reports of ownership of, and transactions in, our equity securities. These reporting persons are further required to provide us with copies of these reports.

Based solely on our review of such reports and written representations by the reporting persons, we believe that during the fiscal year ended December 31, 2025, our directors, officers and owners of more than 10% of a registered class of our equity securities complied with all applicable filing requirements, except that a late Form 4 was filed for Mr. Sipp on June 20, 2025 to report a stock award granted on June 15, 2025 as well as a late Form 4 filed on October 10, 2025 for Mr. Davanzo to report a transfer between accounts for no consideration on September 30, 2025.