Fitzroy Investment Advisors LLC

Item 5 – Fees and Compensation

A. Describe how you are compensated for your advisory services. Provide your fee schedule. Disclose
whether the fees are negotiable.

As compensation for its investment advisory services to Advisory Clients, FitzRoy receives an annual
advisory fee ranging from 0.35% to 0.45% of the assets of Advisory Clients under management with
FitzRoy, generally payable quarterly in arrears. Fees are generally negotiated with each Advisory Client
and, depending on the characteristics of the Advisory Client, may be higher or lower than indicated above.

FitzRoy does not charge a performance fee to its Clients. Accordingly, except to the extent that better
performance increases assets under management and thus the amount of the advisory or management fee,
such fees are payable without regard to the overall success or income earned by Clients.

B. Describe whether you deduct fees from clients’ assets or bill clients for fees incurred. If clients
may select either method, disclose this fact. Explain how often you bill clients or deduct your fees.

FitzRoy does not deduct its fees from Advisory Clients’ assets. Advisory fees are generally paid by
Advisory Clients to FitzRoy pursuant to an advisory agreement between the parties.

Advisory fees may be, and in certain instances have been, waived or modified upon mutual agreement by
FitzRoy and the Advisory Client(s).

C. Describe any other types of fees or expenses clients may pay in connection with your advisory
services, such as custodian fees or mutual fund expenses. Disclose that clients will incur brokerage
and other transaction costs, and direct clients to the section(s) of your brochure that discuss
brokerage.

FitzRoy’s fees are exclusive of other types of fees and expenses (including operating expenses) that may
be chargeable to client accounts such as custodial, administration, brokerage, placement agent, legal and
accounting fees, investment-related expenses (including direct research costs and research-related business
travel costs), liability and other fees and expenses that may be charged by Managers. Assets invested in
Separately Managed Accounts and Investment Vehicles managed by Managers may be subject to both
management and performance fees which are in addition to the fees charged by FitzRoy to its Advisory
Clients. FitzRoy does not share in any fees charged by the Managers.

In addition to the annual advisory fees described above, the Adviser provides certain
non-investment-related services to Clients at the Client’s request. These services may include, without
limitation, customized reporting regarding Client assets, asset reconciliation, data-gathering and
information coordination, administrative services, and communications or coordination with the Client’s
CPA around the annual tax cycle (collectively, “Non-Advisory Services”). Non-Advisory Services are
ancillary and administrative in nature and do not constitute investment advice.

Fees for Non-Advisory Services, are separately negotiated with each Client and are disclosed in the
applicable written agreement with the Client. Such fees may be charged as a fixed fee or as a percentage of
the assets on which FitzRoy reports and are in addition to FitzRoy’s annual advisory fees. Clients are not
required to engage FitzRoy for any Non-Advisory Services as a condition of receiving investment advisory
services.

D. If your clients either may or must pay your fees in advance, disclose this fact. Explain how a client
may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the
billing period. Explain how you will determine the amount of the refund.

Advisory fees applicable to Advisory Clients are paid quarterly in arrears, as described in the investment
advisory agreement between each Advisory Client and FitzRoy.

The services of FitzRoy generally may be terminated by Advisory Clients or FitzRoy at any time, subject
to the particular terms of the respective investment advisory agreement. Upon any such termination, the
Advisory Client will be invoiced a prorated amount of the fees due, calculated to the date of termination.

E. If you or any of your supervised persons accepts compensation for the sale of securities or other
investment products, including asset-based sales charges or service fees from the sale of mutual funds,
disclose this fact and respond to Items 5.E.1, 5.E.2, 5.E.3 and 5.E.4.

   1. Explain that this practice presents a conflict of interest and gives you or your supervised persons
     an incentive to recommend investment products based on the compensation received, rather
     than on a client’s needs. Describe generally how you address conflicts that arise, including your
     procedures for disclosing the conflicts to clients. If you primarily recommend mutual funds,
     disclose whether you will recommend “no-load” funds.

   2. Explain that clients have the option to purchase investment products that you recommend
     through other brokers or agents that are not affiliated with you.

   3. If more than 50% of your revenue from Clients results from commissions and other
     compensation for the sale of investment products you recommend to your clients, including
     asset-based distribution fees from the sale of mutual funds, disclose that commissions provide
     your primary or, if applicable, your exclusive compensation.

   4. If you charge advisory fees in addition to commissions or markups, disclose whether you reduce
     your advisory fees to offset the commissions or markups.

Neither FitzRoy nor its employees receive, directly or indirectly, any compensation in connection with
making or recommending investments for Advisory Client accounts. FitzRoy is compensated solely
through the advisory fee. Accordingly, FitzRoy believes that it does not have any conflicts of interest
regarding the receipt of additional compensation relating to Advisory Client assets that FitzRoy manages,
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Item 7 – Types of Clients

Describe the types of clients to whom you generally provide investment advice, such as individuals,
trusts, investment companies, or pension plans. If you have any requirements for opening or
maintaining an account, such as a minimum account size, disclose the requirements.

FitzRoy provides investment advisory services to high net-worth individuals and trusts on a non-
discretionary basis.

The minimum initial Client ‘liquid’ net worth (i.e. excluding real estate or other non-financial assets) is
generally $15 million. The minimum requirement can be, and in certain instances has been, waived in the
discretion of FitzRoy.