American Trust Investment Advisors LLC

Fees and Compensation

For its advisory services in its separately managed accounts, an annual fee is assessed to clients on a
monthly basis (one-twelfth of the annual fee per month). The monthly assessment is based on the market
value of the client’s account at the end of the previous calendar month (billed in arrears). Management of
ATIA may waive or reduce fees, or account minimum sizes, at its discretion. A 10 percent discount on the
advisory fee is offered to all non-profit organizations.
For traditional separately managed accounts, invested primarily in stocks, bonds and/or cash, the
minimum account size is $500,000. Annual fees for clients with assets of $500,000 or more are 1% (0.9%
for non-profits). If clients make contributions greater than $500,000 during the month, ATIA reserves the
right to bill the client for a pro-rata portion of the assets contributed to the investment account. Clients
may be charged with a pro-rata fee when clients withdraw funds greater than $500,000 from the
investment account during the calendar month.
A client’s agreement may be terminated at the end of any month following thirty days’ prior written
notice from the terminating party to the other party.

The fees charged by ATIA are separate and distinct from the fees and commissions charged by
recommended mutual funds, ETFs, ETNs, brokers, and custodians. A description of these fees is available
in each mutual fund’s, ETF’s, and ETN’s prospectus and from each broker/custodian.

For marketable securities, the prices provided by custodians are used for client reporting and fee billing.
A client could invest in a mutual fund directly, without the services of ATIA. In that case, the client would
not receive the services provided by ATIA which are designed, among other things, to assist the client in
determining which investments are most appropriate to each client’s financial condition and objectives.

Accordingly, the client should review both the total expenses to invest in a mutual fund and the fees
charged by ATIA to fully understand the total amount of fees to be paid by the client and to thereby
evaluate the value of the advisory services being provided.

Rollover Recommendations.

As part of its investment advisory services, ATIA may recommend to a client or a prospective client that
they roll assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account
(collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”). ATIA may also recommend rollovers from IRA
Accounts to Plan Accounts, from Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts.
When ATIA provides any of the aforementioned rollover recommendations it is acting as a fiduciary
within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the
Internal Revenue Code (“IRC”), as applicable, which laws govern retirement accounts. Clients or
prospective clients are under no obligation, contractually or otherwise, to complete these rollover
recommendations. Moreover, if a client or prospective client does complete such a rollover, they are
under no obligation to have the assets in an IRA managed by ATIA.

When ATIA makes a rollover recommendation, it does so under a rule that requires it to act in the best
interests of the client or prospective client, and not to put ATIA’s interests, or those of ATIA’s employees,
ahead of a client’s interest. Under this rule’s provisions, ATIA must:

    •   meet a professional standard of care when making investment recommendations (give prudent
        advice);
    •   never put ATIA’s financial interests ahead of those of a client when making recommendations
        (give loyal advice);
    •   avoid misleading statements about conflicts of interest, fees, and investments;
    •   follow policies and procedures designed to ensure that ATIA gives advice that is in your best
        interest;
    •   charge no more than a reasonable fee for ATIA’s services; and
    •   give clients and prospective clients basic information about conflicts of interest.

Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options
are available, clients and prospective clients should consider the costs and benefits of a rollover.

Note that an employee will typically have four options in this situation:
1. leaving the funds in the employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.

Each of these options has positives and negatives. Accordingly, along with underscoring the importance
of understanding the differences between these types of accounts, ATIA will provide clients and
prospective clients with a written explanation of the advantages and disadvantages of various account

types and, in the instance of a rollover recommendation, the basis for ATIA’s belief that the
recommended rollover transaction is in a client’s or prospective client’s best interests.

Performance-Based Fees and Side-by-Side Management
ATIA does not charge performance-based fees and has no side-by-side management arrangements.

Types of Clients
ATIA provides discretionary investment advisory services to individuals and institutions, including
foundations, not-for-profit organizations, and pension funds. For separately managed accounts, ATIA
typically requires a minimum account size of $500,000, although this minimum may be waived at
management’s discretion.

Methods of Analysis, Investment Strategies, and Risk of Loss
Methods of Analysis: ATIA uses fundamental analysis when researching potential investment candidates.
Sources of research include stock screening using a proprietary analytical framework and an extensive
third-party database, meetings with corporate officers, financial and industry publications, annual
reports, regulatory filings, corporate rating services, and third-party research. ATIA focuses on three
factors when considering investment candidates: (1) a compelling valuation, especially relative to the
growth prospects for a given company and the company’s risk factors, (2) quality management, and (3)
the existence of a catalyst to drive the stock price higher.

Investment Strategies: ATIA selects domestic and foreign stocks for a client’s portfolio that it expects will
appreciate in value over the long term. ATIA uses a “bottom up” approach to stock investing and
generally does not attempt to forecast the U.S. economy, interest rates, inflation, or the U.S. stock
market. It focuses on finding companies that meet their financial criteria, including either a history of
consistent earnings and revenue growth or strong prospects of earnings and revenue growth, and a
strong balance sheet. ATIA purchases the securities of a company with the intention of holding them,
under normal circumstances for the long term. Companies should demonstrate leadership, operating
momentum, and strong prospects for annual growth. ATIA may decide to sell a security due to changes in
fundamentals, such as marked deceleration in earnings growth, decline in revenues or deterioration of
the balance sheet, or a change in a company’s valuation or competitive position.

ATIA expects that most separately managed accounts that invest in individual equity securities (i.e., not
using mutual funds or ETFs) will generally consist predominantly of mid- and large-capitalization stocks,
but in some market environments small-capitalization stocks may constitute a large portion of a portfolio.
ATIA considers a small-capitalization stock to be one with a market capitalization of less than $2 billion at
the time of investment; a mid-capitalization stock to be one with a market capitalization of between $2
billion and $10 billion at the time of investment; and a large-capitalization stock to be one with a market
capitalization of more than $10 billion at the time of investment. ATIA builds individual stock portfolios
through a structured approach to diversification across major economic or market sectors, e.g., consumer
discretionary, consumer staples, energy, financial services, technology, industrials, etc.

ATIA may also invest a significant percentage of client assets in foreign companies, including those in
emerging markets and EAFE (Europe, Australasia, and the Far East), through U.S. listed securities,
depositary receipts, small positions in exchange traded funds or through purchases on foreign exchanges.
Very small portfolios may sometimes use exchange-traded funds if consistent with clients’ screening
preferences.

Fixed Income Securities: With respect to fixed income investments, ATIA carefully considers expected
liquidity needs, upcoming maturities of existing securities, risk tolerance and need for income in
structuring a client portfolio. Fixed income investments are often chosen to fit into a laddered portfolio,
but such laddering will depend in part on the differential of interest rates across maturities.
Risk of Loss: Investing in securities involves risk of loss, which clients should be prepared to bear. The
price volatility of small-cap and mid-cap stocks could be greater than that of large-cap stocks. Investing in
foreign securities, including those that are listed on U.S. exchanges or that trade in the form of depositary
receipts, may represent a greater risk than investing in U.S. securities.