Good Harbor Advisors Inc

Fees and Compensation - Item 5

GHA charges a percentage of assets under management, hourly charges, fixed fees (not including
subscription fees), or other fees for its advisory services.

Portfolio Management Services
If you decide to engage GHA for portfolio management services, we will charge an annual fee based on a
percentage of the market value of the assets being managed. Our fee for portfolio/asset management
services is set forth in the following fee schedule:

Assets Under Management                                  Annual Fee
Up to $300,000                                           1.00%
$300,001 - $900,000                                      0.95%
$900,001 - $2,000,000                                    0.80%
Over $2,000,000                                          0.75%

GHA allows the accounts for members of the same household to be combined for fee-paying purposes.
We combine the account valuations to assist you in meeting fee breakpoints and therefore lowering the
overall fee level. GHA extends this option to all accounts residing in the same household.

GHA will either bill you directly for payment of our fees or the fees will be deducted from your account.
Fees are billed quarterly, in arrears, and are based on the value of your portfolio on the last day of the
quarter. Payment in full is expected upon invoice presentation. Fees are usually deducted from a
designated client asset account to facilitate billing. The client must consent in advance to the direct
debiting of their account.

If you choose to have GHA’s fee deducted directly from your account, you must provide authorization.
The qualified custodian holding your funds and securities will send you an account statement at least
quarterly. This statement will detail account activity. Please review each statement for accuracy. GHA
will also receive a copy of your account statements from the custodian.

Good Harbor Advisors, Inc.
Form ADV Part 2A

Our annual fee is exclusive of, and in addition to, brokerage commissions, transaction fees, and other
related costs and expenses, which will be incurred by the client. However, we will not receive any
portion of the commissions, fees, or costs. Please see Item 12 – Brokerage Practices for further
information on brokerage and transaction costs.

At the inception of investment management services, the first quarter’s fees will be calculated on a pro-
rata basis. The Advisory Agreement between GHA and the client will continue in effect until either party
terminates the Agreement in accordance with the terms of the Agreement. GHA’s annual fee will be
prorated through the date of termination, and any remaining balance shall be charged or refunded to
the client, as appropriate, in a timely manner.

Financial Planning Services
GHA may provide its clients with financial planning and consulting services. GHA will charge a fixed fee
and/or an hourly fee for consulting services. Our consulting fees are negotiable. We utilize the following
financial planning fee schedules:

    •   Fixed Fees: GHA will charge a fixed fee that ranges from $1,000.00 to $10,000.00 for broad-
        based planning services. In limited circumstances, the total cost could potentially exceed
        $10,000.00. In such cases, we will notify the client and may request that the client pay an
        additional fee.

    •   Hourly Fees: GHA charges an hourly fee of $300 for clients who request specific services (such as
        a modular plan or hourly consulting services) and do not desire a broad-based written financial
        plan.

If the client engages GHA for additional investment advisory services, GHA may offset all or a portion of
its fees for those services based on the amount paid for the consulting services.

Prior to engaging GHA to provide consulting services, the client will generally be required to enter into a
written Agreement with us. The Agreement will set forth the terms and conditions of the engagement
and describe the scope of the services to be provided and the portion of the fee that is due from the
client. Generally, GHA requires one-half of the consulting fee (estimated hourly or fixed) payable upon
entering the written Agreement. The balance is generally due upon the completion of the agreed-upon
services. Either party may terminate the Agreement by written notice to the other. In the event the
client terminates GHA’s consulting services, the balance of GHA’s unearned fees (if any) shall be
refunded to the client.

Pension Consulting Services Fees
The compensation arrangement for these services will be based on hourly fees or fees based on a
percentage of assets under management:

    •   Hourly Fees: GHA charges an hourly fee of $300. Our hourly fees are calculated and invoiced to
        the client quarterly in arrears.

    •   Fees Based on a Percentage of Assets: GHA charges an annual fee based on a percentage of the
        market value of the assets in the plan. Fees are set forth in the following fee schedule:

Good Harbor Advisors, Inc.
Form ADV Part 2A

        Plan Assets                                Annual Fee
        Up to $1,000,000                           0.25%
        $1,000,001 - $3,000,000                    0.20%
        Over $3,000,000                            0.15%

Fees are paid by the plan administrator on a quarterly basis, in arrears. If you choose to have GHA’s fee
deducted directly from your account, you must provide authorization. The qualified custodian holding
your funds and securities will send you an account statement quarterly. This statement will detail
account activity. Please review each statement for accuracy. GHA will also receive a copy of your
account statements from the custodian.

Pension Consulting Services will be negotiated on a case-by-case basis, and the exact fee paid by the
client and the payment arrangements will be clearly stated in the pension consulting Agreement signed
by the client and the firm.
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Types of Clients - Item 7

We offer investment advisory services to individuals, pension and profit-sharing plan participants, trusts,
estates, charitable organizations, corporations, and other business entities.

GHA has no minimum requirements for opening or maintaining an account.

                  Methods of Analysis, Investment Strategies and Risk of Loss - Item 8

The following are different methods of analysis that we may use when providing you with investment
advice:

    •   Fundamental Analysis – fundamental analysis is a technique that attempts to determine a
        security’s value by focusing on underlying factors that affect a company's actual business and its
        future prospects. The term refers to the analysis of the economic well-being of a financial entity
        as opposed to only its price movements.
    •   Technical Analysis – technical analysis is a technique that relies on the assumption that current
        market data (such as charts of price, volume, and open interest) can help predict future market
        trends, at least in the short term. It assumes that market psychology influences trading and can
        predict when stocks will rise or fall.
    •   Cyclical Analysis – cyclical analysis is a technique that looks at cycles, specifically analyzing the way
        prices follow certain patterns and trends.

Good Harbor Advisors, Inc.
Form ADV Part 2A

We may use one or more of the following investment strategies when advising you on investments:

    •   Long Term Purchases – securities held for over a year.
    •   Short Term Purchases – securities held for less than a year.
    •   Trading – securities held for less than 30 days.

Although trading is not used as part of GHA’s overall investment strategy, Associated Persons of the Firm
may employ this strategy on a limited basis where they determine that this strategy is suitable given the
client’s stated investment objectives and risk tolerance.

The investment advice provided along with the strategies suggested by GHA will vary depending on each
client’s specific financial situation and goals. This brief statement does not disclose all of the risks and
other significant aspects of investing in financial markets. In light of the risks, you should fully
understand the nature of the contractual relationship(s) into which you are entering and the extent of
your exposure to risk. Certain investing strategies may not be suitable for many members of the public.
You should carefully consider whether the strategies employed would be appropriate for you in light of
your experience, objectives, financial resources, and other relevant circumstances.

General Investment Risk: All investments come with the risk of losing money. Investing involves
substantial risks, including possible complete loss of principal, plus other losses, and may not be suitable
for many members of the public. Investments, unlike savings and checking accounts at a bank, are not
insured by the government to protect against market losses. Different market instruments carry different
types and degrees of risk, and you should familiarize yourself with the risks involved in the particular
market instruments you intend to invest in.

Loss of Value: There can be no assurance that a specific investment will achieve its investment
objectives, and past performance should not be seen as a guide to future returns. The value of
investments and the income derived may fall as well as rise, and investors may not recoup the original
amount invested. Investments may also be affected by any changes in exchange control regulations, tax
laws, withholding taxes, international, political and economic developments, and government,
economic, or monetary policies.

Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income
securities may fall in value if interest rates change. Generally, the prices of debt securities rise when
interest rates fall, and their prices fall when interest rates rise. Longer-term debt securities are usually
more sensitive to interest rate changes.

Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the
issuer(s) may not make required interest payments. An issuer suffering an adverse change in its financial
condition could lower the credit quality of a security, leading to greater price volatility of the security. A
lowering of the credit rating of a security may also offset the security's liquidity, making it more difficult
to sell. Funds investing in lower-quality debt securities are more susceptible to these problems, and
their value may be more volatile.

Foreign Exchange Risk: Foreign investments may be affected favorably or unfavorably by exchange
control regulations or changes in the exchange rates. Changes in currency exchange rates may influence
the share value, the dividends or interest earned, and the gains and losses realized. Exchange rates

Good Harbor Advisors, Inc.
Form ADV Part 2A

between currencies are determined by supply and demand in the currency exchange markets, the
international balance of payments, governmental intervention, speculation, and other economic and
political conditions. If the currency in which a security is denominated appreciates against the US Dollar,
the value of the security will increase. Conversely, a decline in the exchange rate of the currency would
adversely affect the value of the security.

Futures and Options: Options and futures contracts on securities carry a high degree of risk. The
amount of the initial margin is small relative to the value of the futures contract, so that transactions are
"leveraged" or "geared.” A relatively small market movement will have a proportionately larger impact,
which may work for or against the investor. The placing of certain orders, which are intended to limit
losses to certain amounts, may not be effective because market conditions may make it impossible to
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