Hendley & Co Inc

Item 5 Fees and Compensation

As of June 1, 2018, new clients will be charged for services provided by Hendley &
Company, Inc. based on the following schedule.

               Annual Rate                   Assets Under Management
               1.00%                         First $500,000
               0.90%                         Next $500,000 to $1,500,000
               0.75%                         Next $1,500,000 to $5,000,000
               0.50%                         Balances over $5,000,000

Money that is swept or transferred into money market mutual funds is subject to an
advisory fee, plus the money market mutual funds’ management fee and operating fees.
Under no circumstances do we receive compensation from any investment companies. Fees
are computed and billed at one-fourth of the annual rate quarterly, at the end of each
calendar quarter. In certain circumstances we may negotiate fees and account minimums.
Hendley & Company, Inc., at its discretion, may consider total family/entity relationship
when negotiating fees, but is not obligated to do so. Some clients pay amounts other than
the above, pursuant to fee schedules in place at the time the clients entered into advisory
agreements with us. Further, fees for some clients have been waived or reduced as a result
of the relationship with the firm, including employees and family members. No prepayment

of fees is accepted. Accounts initiated or terminated during a calendar quarter will be
charged a prorated fee.

Clients may elect to be billed directly for fees or to authorize Hendley & Company, Inc. to
directly debit fees from client accounts.

Hendley & Company, Inc.’s fees are exclusive of brokerage commissions, transaction fees,
and other related costs and expenses which shall be incurred by the client. Clients may
incur certain charges imposed by custodians, brokers, third party investment and other third
parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes
on brokerage accounts and securities transactions. Mutual funds and exchange traded funds
also charge internal management fees, which are disclosed in a fund’s prospectus. Such
charges, fees and commissions are exclusive of and in addition to our fee, and we shall not
receive any portion of these commissions, fees and costs.

As of October 1, 2025, fees assessed by our custodian, Pershing, changed to an asset-based
model from the previous transaction-based model. A quarterly asset-based brokerage
charge not to exceed 5 basis points will be billed in advance, based on the value of the
portfolio over the previous quarter. The value will be calculated from the average of the
previous three-month end values for all assets in the account as determined by Pershing’s
asset-based billing engine. FundVest, Alternatives, and Cash/bank deposit products shall be
excluded from chargeable assets. 529 assets shall be excluded from billing. A quarterly
minimum of $30 per quarter per account will apply.

As of January 1, 2026, in instances where investors utilize a Securities Account Control
Agreement (“SACA”) to pledge assets custodied at Pershing as collateral for a loan from a
third-party lender, a fee not to exceed 10 bps annually will be assessed and charged
monthly to their accounts based on the total value of the assets held in accounts subject to
an active SACA at the end of each billing month.

The custody fees described above are not paid to Hendley & Company, Inc. and are
separate and distinct from advisory fees charged by Hendley & Company, Inc. which are
outlined above and described in each client’s management agreement. Hendley & Company
is not affiliated with Pershing. For additional information about Pershing, Hendley &
Company, Inc. directs its clients to Pershing’s disclosure documents.

Item 7 Types of Clients

Hendley & Company, Inc. provides portfolio management services to individuals, high net
worth individuals, corporate pension and profit –sharing plans, corporations, charitable
institutions, foundations and trusts. We, at our sole discretion, may accept clients with
portfolios under $100,000 based upon certain factors including: (a) anticipated future
earning capacity (b) anticipated future additional assets (c) account composition (d) related
accounts (e) pre-existing client relationship.