Breakwater Investment Management LLC

Item 5 - Fees and Compensation

Fees for Investment Advisory Services

The specific manner in which fees are charged by us is established in your written investment advisory agreement. We
generally bill fees on a monthly basis in arrears. Fees are deducted directly from your investment accounts in
accordance with the written authority granted in our advisory agreement and/or the account opening documentation
of your custodian. Our asset-based advisory fees are based on a percentage of the market value of your assets at the
close of business on the last business day of the month as determined by the custodian. Fees are prorated for capital
contributions and withdrawals made during the applicable calendar month. You share responsibility for verifying the
accuracy of fee calculations.

Our standard fee schedule for Investment Advisory Services is as follows:

     •    1.25% on entire balance for assets up to $500,000;
     •    1.00% on entire balance for assets between $500,001 and $1,000,000; and
     •    0.85% on entire balance for assets between $1,000,001 and $5,000,000
     •    Fees on assets in excess of $5,000,000 are negotiable

As described above, fees for investment advisory services will be directly deducted from your account at the qualified
custodian of your assets. The custodian will send you an account statement on a monthly basis identifying the amount
of funds and each security in your account at the end of the period and setting forth all transactions in the account
during the period, including the amount of any advisory fees paid directly to us. Clients are advised that the custodian
will not verify our fee calculations. Accordingly, clients are encouraged to review the custodian’s account statements
promptly upon receipt to confirm the accuracy of our fees. If you believe there has been an error or have any other
questions regarding your accounts, please contact us promptly at the telephone number on the cover page of this
brochure.

Fees for Use of Sub-Adviser

Ethic shall waive the management fee on assets in the client accounts held in Model Portfolios for which SSGA serves
as investment adviser (“SSGA Model Portfolios”) (the “Management Fee Waiver”). Thereafter, we must maintain an
Aggregate client account value greater than or equal to fifty million dollars ($50,000,000) of assets in client accounts
held in Model Portfolios (the “Fee Waiver Minimum”), otherwise Ethic will have the right to terminate the Management
Fee Waiver. For the avoidance of doubt, assets in client accounts held in SMA Portfolios will not be eligible for the
Management Fee Waiver nor shall they be included as part of the Aggregate client account value needed to satisfy the
Fee Waiver Minimum.

Version date: March 31, 2026               Breakwater Investment Management                           Page 7 of 19

Fees for Financial Planning Services

In general, planning services are offered without additional charge to investment advisory clients. For noninvestment
advisory clients, fees for planning services are based on an hourly rate of $350.00 per hour or a flat fee of $2,500.00 to
$20,000.00, based on the complexity of the engagement. We occasionally do pro bono (free) planning for clients, based
on their financial need. Special arrangements may be made with you should you wish to retain financial planning
services on an ongoing basis.

Fees for Trustee Services
Trustee services will be calculated and quoted on a per account or relationship basis. Pricing will be impacted by
reporting complexity, whether Breakwater is also managing the assets, and general attractiveness of the engagement.

Other Fees and Costs

Our advisory fees cover the costs of our investment advice only and are exclusive of brokerage commissions,
transaction fees, custodial fees and charges, taxes, margin expenses, wire fees, fund internal fees, fund early
redemption fees, and other related costs and expenses which shall be incurred by the client. In practice, we try to avoid
or keep these fees as low as possible for our clients and try to provide proactive disclosures when possible.

Fee Negotiation

Notwithstanding the above, all fees are negotiable on a client-by-client basis. Not all clients will pay the same fee.

Terminating Engagements

You can terminate our engagement at any time by giving us written notice (e-mail or letter). For investment advisory
services, your account will be charged for the days prior to receipt of your notice. For financial planning services, you
will be charged for the number of hours of service provided prior to termination (in the case of hourly fees) or our good
faith determination of the value of services provided prior to termination (in the case of flat fees). In all cases we will be
cooperative in resolving disputes and helpful if you wish to move your investments to the care of another firm. Our goal
is excellent service any time you work with us, whether you are engaging us or leaving us.

Compensation for Sales of Securities

Breakwater and its associated persons do not receive or accept any compensation for the sale of any securities or
investment products.

Item 7 - Types of Clients

It is more important to us to work with people who are pleasant in nature and kind to animals and nature, than those
who meet a threshold level of wealth or investable assets. We provide portfolio management services to individuals,
high net worth individuals, qualified retirement plans, trusts, non-profit organizations, and businesses. We provide
financial planning services to individual clients.

For all new client relationships, we require a minimum annual fee of $5,000 to commence or continue an advisory
relationship, though we may waive this requirement for certain clients at our discretion. Existing clients are exempt
from this requirement. We do not maintain any minimum amount of assets to commence or continue an advisory
relationship.

For clients that participate in Ethics investment strategy, the minimum size for client accounts is $50,000. This
minimum is also waivable at our discretion.