Cavalier Investments LLC

Item 5. Fees and Compensation

The Adaptive Investments Funds

Pursuant to an advisory agreement between Adaptive Investments and the Starboard Investment Trust (the “Trust”)
on behalf of each Fund, each Fund pays Adaptive an advisory fee at a maximum annualized rate of 1.00% which is
calculated daily and paid monthly, based on its average daily net assets. The minimum fee charged is .45%. When
a Fund is subadvised, a portion of the advisory fee is paid to the subadvisor.

Adaptive Investments has entered into an Expense Limitation Agreement with the Funds under which it has agreed
to waive or reduce its fees and to assume other expenses of the Funds, if necessary, in an amount that limits the
Fund’s annual operating expenses (exclusive of interests, taxes, brokerage fees and commissions, extraordinary
expenses, and payments under the Rule 12b-1 distribution plan including, and acquired fund fees and expenses).
Net annual operating expenses for the Fund may exceed these limits to the extent that it incurs expenses enumerated
above as exclusions. The Expense Limitation Agreement originally expiring on September 30, 2024, was renewed
until September 30, 2025, and may not be terminated prior to that date except via action of the Starboard’s Trust’s
board of trustees. The Adviser cannot recoup from the Fund any amounts paid by Adaptive Investments under the
Expense Limitation Agreement.

Potential investors should review the appropriate Fund’s prospectus and Statement of Additional Information
(“SAI”) for additional information on Adaptive Investments 's compensation.

Model Portfolio

Adaptive Investments receives a fee from platforms that utilize its model portfolio strategy at an annual rate of 0.00-
0.50% of the assets invested in the portfolio strategy which is calculated and paid on at least a quarterly basis.

General Disclosure

Adaptive Investments Funds that invest in mutual funds or exchange traded securities such as ETFs also pay,
indirectly, investment advisory fees to the managers of those funds and those exchange traded securities.

Adaptive Investments believes that its fees are competitive with fees charged by other investment advisers for
comparable services. Comparable services may be available, however, from other sources for lower fees.

In all cases, the pro rata portion of the management fee through the date of termination is charged to the client
account. All prepaid but unearned advisory fees are refunded on termination of a client’s account.

Each account is responsible for its own costs and expenses, including trading costs and expenses (such as brokerage
commissions, expenses related to short sales, and clearing and settlement charges), ongoing legal, accounting and
bookkeeping fees and expenses, and the fees and expenses charged by any fund administrator for its accounting,
bookkeeping and other services. Adaptive Investments bears its own operating, general, administrative and
overhead costs and expenses, other than the expenses described above.

Retirement Plan Assets

Certain retirement plans can be billed monthly based upon ending account value for the period due at a rate of 4-
10bps per annum. In such instances, the engagement agreement will spell out the billing arrangement, whether in
advance or arrears, and whether based on the account value as of month-end of the plan’s assets.

Item 7. Types of Clients

Adaptive Investments provides investment advice to the Funds. Adaptive Investments may provide investment
advice as a sub-adviser to financial intermediaries. Adaptive Investments may also provide investment advice to
retirement plan sponsors regarding the allocation of assets among plan investment options.