Ashdon Investment Management LLC

Item 5 – Fees and Compensation

The specific manner in which fees are charged is established in a client’s written
investment management agreement. Clients may terminate their investment
management agreement at the end of any calendar month with at least 30 days written
notice. Upon termination, any fees paid in advance, but not yet earned shall be refunded
to the client on a pro rata basis. Any fees due will be payable.

Clients may, but are not required to, grant Ashdon the authority to debit advisory fees
directly from the clients’ accounts. If the client authorizes Ashdon to debit fees, Ashdon
is deemed to have custody of the client’s funds. Clients will receive a statement, usually
monthly but no less than quarterly, directly from their account custodian. Ashdon urges
clients to review the information on the statement for accuracy and compare the
information to any reports received directly from Ashdon. Please refer to the Custody
section of this document for additional disclosures relating to the deduction of advisory
fees.

Ashdon Investment Management’s 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, and other third
parties such as 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 indirectly charged to the client. Such charges, fees and
commissions are exclusive of and in addition to Ashdon Investment Management’s fee,
and Ashdon Investment Management shall not receive any portion of these commissions,
fees, and costs.

Item 12 further describes the factors that Ashdon Investment Management considers in
selecting or recommending broker-dealers for client transactions and determining the
reasonableness of their compensation.

Separate Accounts: The standard fee schedule for management of a separate account
is 1% annual fee paid quarterly in advance, based on the market value of the portfolio on
the first day of each calendar quarter. Fees may be negotiable at Ashdon’s sole
discretion. Fees for separate account management are directly debited from clients’
account.

To the extent that Ashdon recommends clients engage a third party manager or invest in
any private funds, the client would be required to enter into a separate investment
management agreement directly with the manager or complete the fund’s subscription
documents. The client would be subject to the investment management fees (and any
incentive fees) charged by the fund or third party manager, which would be disclosed to
the client in advance.

In limited circumstances, Ashdon may have the discretion to engage third party managers
or invest in private funds on behalf of the client. In such cases, the client will be subject
to all the fees and expenses associated with such investments. Ashdon considers the
costs associated with each investment when determining if the investment is appropriate
for the client’s portfolio.

Consulting Services: Fees for consulting services are negotiable and depend on the
nature and scope of the services provided by Ashdon. Consulting fees may be based on
a percentage of assets under management or a fixed fee arrangement. Consulting fees
are paid quarterly in advance. Clients may choose to receive an invoice or have fees
directly debited from their account.

Family Office Services: Fees for family office services are negotiable based on the nature
and scope of the services provided by Ashdon. Fees are typically based on a fixed or
asset based fee arrangement, but may also be included in the consulting services fee
described above. The specific fees are described in the advisory agreement between
Ashdon and the client.

Item 7 – Types of Clients

Ashdon Investment Management offers its advisory services to individuals, high net worth
individuals, trusts, estates, and charitable organizations. The minimum account size
required for each of the advisory services offered follows. Ashdon may choose to waive
any minimum requirement at its discretion.

              Separate Account                 $100,000
              Consulting Services             $20 million