Harvey Investment Company LLC

FEES AND COMPENSATION

Harvey is typically compensated for its investment advisory services by charging you a management fee
based on the market value of your assets under our management based upon the fee schedule set forth
below:

                   First $1,000,000 of assets     1% per annum
                   Next $2,000,000 of assets .75% per annum
                   Assets above $3,000,000 .50% per annum

However, our fee for clients who participate in our Harvey Focus Portfolios is 1% of the market value of
the assets which participate in this service regardless of the total value of the assets. Harvey Focus
Portfolios are portfolios with a higher degree of concentration, focused on mid-sized companies.

Fees are billed quarterly in advance based upon the market value of the assets at the end of the
preceding quarter. If your relationship with us is begun or ended during a calendar quarter, your fee will
be prorated for the appropriate number of days completed or remaining in the quarter and, where
applicable, you will be issued a refund for the portion of your quarterly fee paid in advance which was
unearned.

Fees for non-discretionary services are agreed to the time of our engagement and will vary from client
to client.

We may negotiate the amount of your fee depending upon circumstances including but not limited to
account composition and complexity, other client, employee or family relationships, etc. which may
result in different fees being charged by us for client accounts similar in composition and objectives.
Our employees and their family related accounts may be charged a reduced fee, or no fee, for our
services.

You may pay your fee to us directly upon receipt of an invoice from us or you may authorize your
custodian to allow us to directly debit our fee from your account or accounts. If you choose the latter

method, your custodian will not confirm our fee but will pay the amount based on the fee amount
communicated to the custodian by us and send it directly to us. You will receive a periodic statement
from your custodian which will include the amount of the fee which has been sent to us. You should
confirm the accuracy of our fee calculation upon receipt of your custodian’s statement.

The fees you pay us do not include brokerage commissions or other fees or charges associated with
securities transactions implemented with or through a brokerage firm, mark-ups or mark-downs in
principal transactions, deferred sales charges, stock exchange fees, wire transfer or related processing
fees, transfer taxes or other charges mandated by law or regulation all of which will be charged to you in
addition to our fee. We do not receive any portion of any of the foregoing expenses or fees. You should
refer to the section on Brokerage Practices in our brochure for more information on how we select or
recommend brokerage firms for your securities transactions and information related to that process.

You should understand that mutual funds, including exchange traded funds, in which your assets are
invested by us or by others, impose separate investment management fees and other operating
expenses, described in the fund’s prospectus, for which you, the client, will be charged separately from
the fee paid to us for our services.

Clients should be aware that similar or comparable services may be available from other firms including
other investment management firms at a cost higher or lower than that available through us.

PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT

This section does not apply to Harvey Investment Company, LLC.

TYPES OF CLIENTS

Our clients include individual persons, pension and profit-sharing plans, trusts, estates, charitable
organizations and corporations or similar business entities. Generally, our minimum account size is
$500,000 although this may be waived based on other considerations such as the account’s relationship
to established clients or other factors.

METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS

We use several methods of investment analysis and investment strategies to provide services to our
clients but our primary method consists of fundamental analysis which is the analysis of a company’s
financial statements, its management, competitive advantages, markets, etc. Our investment strategies
include long term purchases (securities generally held for at least a year) and short-term purchases
(securities generally held for less than a year).

The securities we use in our investment strategies and investment advice include equity securities such
as exchange listed securities, securities traded over the counter and foreign issues; warrants; debts
securities of corporations and similar entities; commercial paper; certificates of deposit; municipal and
government securities; and investment company securities such as mutual fund shares. From time to
time, we may sell call options on a stock or stocks in your account.

Investing in securities such as the types of securities used by us in managing your assets or providing you
investment advice involves the potential risk of loss in the value of the securities both in the amount
invested in the securities as well as any profits which have not been realized by selling the securities.
You should be prepared to bear the risk of such losses. The degree of risk depends upon the type of
security or strategy involved.

DISCIPLINARY HISTORY

This section does not apply to Harvey Investment Company, LLC or any of its employees.

OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS

The following firms are affiliated with Harvey based on common ownership interest through our
majority owner, WealthTrust Acquisition, LLC:

Delta Asset Management, LLC ‐ investment adviser
Duncker Streett & Co., LLC – investment adviser
Kanawha Capital Management, LLC – investment adviser
WealthTrust Axiom, LLC – investment adviser
Hightower Securities, LLC – broker-dealer
Hightower Advisors, LLC – investment adviser
Hightower Trust Company N.A. – trust company
Madison Avenue Financial Solutions, LLC – investment adviser
Grant Tani Barash & Altman, LLC – investment adviser
Hightower Trust Company of Illinois, LLC – trust company
NEPC, LLC – investment adviser
GMS Surgent Advisors, LLC – accounting firm

However, Harvey does not have a relationship or arrangement with any of these affiliated firms which is
material to our business or to our clients.

CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING

Harvey has adopted a written Code of Ethics under which all our full-time employees are generally
restricted from effecting transactions in certain securities for their personal accounts absent written
pre-approval in order to seek to avoid conflicts of interest with transactions being effected in client
accounts. Our employees may buy or sell the same securities that we recommend that our clients invest
in or that we purchase or sell on our clients’ behalf. This presents a conflict of interest between our
employees’ own financial interest and the best interest of our clients. We have addressed this conflict
of interest by imposing trading restriction under the Code of Ethics described above in this section which
include restrictions on our employees’ personal trading based upon investment activity occurring in, or
being contemplated for, our clients’ accounts. Pre-approval must also be obtained by employees before
investing in initial public offerings of securities and before investing in a private placement of securities.
Our employees are required to submit quarterly reports relating to their personal transactions and
personal securities holdings to us. Our Code of Ethics also contains policies and procedures which are
intended to prevent the misuse of material non-public information. A copy of our Code of Ethics is
available to you upon request by contacting us through the contact information provided on the Cover
Page of this brochure.