Alhambra Investment Management LLC

Item 5 – Fees & Compensation
All fees are subject to negotiation.

The specific manner in which fees are charged by AIM is established in a client’s written
agreement with the firm. AIM will generally bill its fees on a quarterly basis in advance. Clients
may elect to be billed directly for fees or to authorize AIM to directly debit fees from client

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accounts. Management fees shall be prorated for each capital contribution and withdrawal made
during the applicable calendar quarter (with the exception of de minimis contributions and
withdrawals). Accounts initiated or terminated during a calendar quarter will be charged a prorated
fee. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and
any earned, unpaid fees will be due and payable.

A minimum of $250,000 of assets under management is required to establish a client relationship
with AIM. Account size may be negotiable under certain conditions.

AIM management fees are exclusive of brokerage commissions, transaction fees, and other
related costs and expenses which shall be incurred by the client. Clients may incur certain charges
imposed by custodians, brokers, third party investment and other third parties such as fees
charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes,
wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
securities transactions. Mutual funds and exchange traded funds also charge internal
management fees, which are disclosed in a fund’s prospectus. Such charges, fees, and
commissions are exclusive of and in addition to AIM’s fee.

Neither AIM nor any of its supervised persons accept compensation for the sale of securities or
any investment products.

Item 12 further describes the factors that Alhambra Investment Management considers in
selecting or recommending broker-dealers for client transactions and determining the
reasonableness of their compensation (e.g., commissions).

Fee Schedule

       1.25% for the first $500,000
       Plus 1% for additional assets up to $3 million
       Plus 0.75% for additional assets up to $5 million
       Negotiable for assets managed above $5 million

Item 7 – Types of Clients
Alhambra Investment Management provides portfolio management services to individuals, high
net worth individuals, charitable organizations, and corporations.

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