Compass Capital Management LLC

Item 5 – Fees and Compensation.

Cambridge Investment Research, Inc.
Clients choosing to implement Compass Capital Management’s advice are free to select any broker they
wish and are so informed. If clients wish to have our advisor representatives implement advice in their
capacity as registered representatives or through our Asset Management Program, Cambridge will be
used. Not all investment advisors require the use of a particular broker/dealer. Some investment
advisors allow their clients to pick which broker/dealer the client uses. However, in order to provide
efficient services and based on the arrangement with Cambridge, Compass Capital Management requires
the use of Cambridge when opening an account through the firm’s Asset Management Services program.

Our advisor representatives are registered representatives of Cambridge and are required to use the
services of Cambridge and Cambridge’s approved clearing broker-dealers when acting in their capacity
as registered representatives. Cambridge serves as the introducing broker-dealer. All accounts
established through Cambridge will be cleared and held through National Financial Services, LLC or
Pershing, LLC. Cambridge has a wide range of approved securities products for which Cambridge
performs due diligence prior to selection. Cambridge’s registered representatives are required to adhere
to these products when implementing securities transactions through Cambridge. Commissions charged
for these products may be higher or lower than commissions clients may be able to obtain if transactions
were implemented through another broker/dealer. Because some of the associated persons of Compass
Capital Management are also registered representatives of Cambridge, Cambridge provides compliance
and supervision support to the associated persons of Compass Capital Management. In addition,
Cambridge also provides the associated persons of Compass Capital Management, and therefore
Compass Capital Management, with back-office operational, technology, and other administrative
support.

For clients with accounts reviewed under our Advisement Program, we do not select or determine the
broker/dealer or qualified custodian for your account. You can select a broker/dealer of your own
choosing. For such accounts, we are not able to negotiate execution costs and fees charged to your
account. You may receive less favorable prices than would otherwise be the case if you had selected a
different broker/dealer or custodian. You are responsible for trades in such accounts, and we will not
have access to your account or authorization over your account to affect transactions.

Cambridge Equity Participation Plan
In addition, Jimmy Williams has entered into an Equity Participation Plan with Cambridge. Under this
arrangement, he has the ability to earn a percentage of Cambridge’s overall profit ratio. Jimmy Williams
is not an owner or officer of Cambridge. However, he is eligible to participate in the Equity Participation
Plan due to his affiliation as a registered principal of Cambridge. This arrangement between Mr. Williams
and Cambridge is a conflict of interest between Compass Capital Management and its clients in that it
can inhibit Compass Capital Management’s independent judgment concerning the best execution
services offered by Cambridge. As of the date of this document, Jimmy Williams has not exercised his
right to participate in the Equity Participation Plan.

Block Trading Policy
Transactions implemented by Compass Capital Management for client accounts are generally effected
independently unless the firm decides to purchase or sell the same securities for several clients at
approximately the same time. This process is referred to as aggregating orders, batch trading or block
trading and is used by the firm when Compass Capital Management believes such action may prove

Compass Capital Management                                                      Form ADV Part 2A: Firm Brochure

advantageous to clients. When Compass Capital Management aggregates client orders, the allocation of
securities among client accounts will be done on a fair and equitable basis. Typically, the process of
aggregating client orders is done in order to achieve better execution, to negotiate more favorable
commission rates or to allocate orders among clients on a more equitable basis in order to avoid
differences in prices and transaction fees or other transaction costs that might be obtained when orders
are placed independently. Under this procedure, transactions will be averaged as to price and will be
allocated among the firm’s clients in proportion to the purchase and sale orders placed for each client
account on any given day. When Compass Capital Management determines to aggregate client orders
for the purchase or sale of securities, including securities in which Compass Capital Management may
invest, the firm will do so in accordance with the parameters set forth in the SEC No-Action Letter, SMC
Capital, Inc. (found at https://www.sec.gov/divisions/invesment/noaction/1995/smccapital090595.pdf. It
should be noted, Compass Capital Management does not receive any additional compensation or
remuneration as a result of aggregation.

Item 7 – Types of Clients

Compass Capital Management generally provides investment advice to the following types of clients:

    •   Individuals
    •   High-Net Worth Individuals
    •   Pension and profit sharing plans
    •   Trusts, estates, or charitable organizations
    •   Corporations or business entities other than those listed above

All clients are required to execute an agreement for services in order to establish a client arrangement
with Compass Capital Management and/or the sponsor of third-party money manager platforms.

Compass Capital Management                                                        Form ADV Part 2A: Firm Brochure

Minimum Investment Amounts Required
Compass Capital Management requires a minimum investment amount of $25,000 to contract for Asset
Management Services. Exceptions to this minimum may be granted at the discretion of the firm.