Copley Investment Management LLC

Item 5: Fees and Compensation Disclosure

CIM fees are disclosed to each client in the client’s original “Letter of Agreement”, with copies
provided to each client, as well as in the quarterly reports each client receives in a timely manner.
Copley Investment Management calculates fees according to the methodology stated in the
agreement.

Fees
Fees are generally not greater than 2% per annum, payable quarterly in arrears, of the market value of
assets under management, although fees may be negotiable such as fixed fees, which are payable
quarterly. Financial consulting services, including expert witness testimony are billed hourly generally at
$250 per hour, Business Valuations and Expert Witness Services are payable at the time of service. CIM
never bills investment clients for fees in advance of service except a retainer for Valuations.
When transacting individual securities, CIM uses discount on-line trading whenever possible. If you
direct CIM to use a full-service broker, CIM attempts to negotiate trade discounts. Copley Investment
clients may invest in products, which CIM recommends through other brokers, or agents who are not
affiliated with CIM.

Fee Arrangement

Clients may choose to have their balance deducted from their account or to pay CIM directly

Item 6: Performance Base Fees

 Copley Investment Management does not accept any Performance Base Fees. CIM does not engage
in market timing.

Item 7: Types of Clients

 Copley Investment Management provides advisory services to approximately 537 clients. The
 majority of Copley Investment Management’s clients are families and individuals. A small percentage
 of clients are Pension and Profit-Sharing Plans, and Corporations. Copley Investment Management
 does not sponsor pooled vehicles (e.g., hedge funds).