Beaton Management Co Inc

Fees and Compensation
Description
       Beaton Management bases its fees on a percentage of Assets Under Management or hourly
       charges. Asset management fees are calculated on the following schedule:

                                First $100,000           @       1.5%
                                Second $100,000          @       1.0%
                                Third $100,000           @       0.8%
                                Next $200,000            @       0.6%
                                Over $500,000            @       0.4%

Fee Billing
        Fees are negotiable between Beaton Management and the client. Fees are billed quarterly in
        arrears. Clients may choose to have fees deducted quarterly from a designated brokerage account
        at their qualified custodian to facilitate billing, or to be invoiced quarterly. The client must
        consent in advance to direct debiting of their investment account.

Other Fees
       Custodians may charge transaction fees on purchases or sales of certain mutual funds, stocks,
       bonds, and exchange-traded funds. In some cases, custodians also charge monthly, quarterly or
       annual custody fees. Fees for custody are disclosed to clients when this type of arrangement is
       recommended.

        Mutual funds and exchange traded funds generally charge a management fee for their services as
        investment managers. The management fee is included in the expense ratio. Mutual fund fees
        also include transaction charges for the purchase or sale of securities within the fund and may
        charge other fees as disclosed in the fund prospectus. These fees are in addition to the fees paid
        by the client to Beaton Management.

        Please see the section entitled “Brokerage Practices” on page 4 for more information.

Compensation for Sales of Investment Products
     The firm’s compensation is solely from fees paid directly by clients. The firm does not receive
     commission based on the client’s purchase of any financial product, including insurance. No
     commissions in any form are accepted.

Types of Clients
Description
       Beaton Management provides investment services to individuals, families, trusts, estates,
       foundations, charitable organizations, and corporations. Beaton Management does not impose a
       minimum dollar value on assets or other condition for opening or maintaining an account.

Methods of Analysis, Investment Strategies, and Risk of Loss
Description
       Beaton Management primarily invests in equity securities, U.S. Treasury and other obligations of
       the U.S. Government, municipal bonds, corporate debt securities, Exchange Traded Funds
       (ETFs), mutual funds, hedge funds, and structured products. Use of option strategies are made
       upon instructions from the client.