Heward Investment Management Inc

ITEM 5: FEES AND COMPENSATION

A.       Compensation for Advisory Services

The specific advisory fees charged by Heward will be documented in each client’s written
advisory agreement. Heward bills its management fees on a monthly basis in arrears based on
the previous month-end market value of the assets managed by Heward. Heward’s standard
management fee rate is 1% on the first $2 million in assets under management, 0.75% on the
next $3 million, and 0.50% on the excess of the value of the assets managed by Heward. In
certain circumstances, advisory fees are negotiable.

B.       Billing Method

Fees are deducted directly from clients’ accounts at the custodian on a monthly basis. These
advisory fees are remitted by the custodian to Heward. You are encouraged to verify the
accuracy of fee calculations and compare the statements provided to you by Heward with the
statements from the custodian(s). The custodian may not verify the accuracy of the advisory
fees charged to you.

C.       Other Fees and Expenses

In addition to the advisory fees paid to Heward, clients may also incur additional fees and
charges, including securities brokerage commissions, custodial fees, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions.

D.       Termination of Services

Heward does not bill any fees in advance. Either the client or Heward may terminate the Firm’s
services without penalty at any time. When terminating an advisory agreement, Heward is
required to provide 30 days notice to the client. Heward ceases to charge management fees on

Heward Investment Management Inc.
Form ADV Part 2A                                                                        June 26,2024

the day they receive notice of the closing of an account either directly from the client or when a
transfer out form is received from another institution.

E.      Outside Compensation for Sale of Securities

Heward does not accept compensation for the sale of securities or other investment products
or for the recommendation of other investment advisors.

ITEM 7: TYPES OF CLIENTS

Heward provides advisory services primarily to individuals, family trusts, estates, holding
companies, non-resident companies, and charitable foundations. As noted above, Heward also
offers Canadian pooled funds (the Heward Funds) to Canadian clients. Heward has a minimum
account size of $500,000, which may be waived in certain cases, such as if a client has related
accounts under management by the Firm.