Keel Capital AB

Item 5.        Fees and Compensation
Details of both management fees and performance fees/incentive allocations for each Fund and U.S.
SMA are set out in detail in the respective Fund’s Offering Documents and investment management
agreements, and outlined below.

Foghorn Fund
Subscription Fee / Redemption Fee / Conversion Fee
(Expressed in percentage of the relevant Initial Subscription Price / Net Asset Value per Share)

Class                 EUR(C)         H-SEK(C)        H-USD(C1) H-USD(C2) H-NOK(C)
Subscription Fee      None           None            None      None      None
Redemption Fee        None           None            None      None      None

Conversion Fee        EUR 100         SEK 1,000       USD 1,000     USD 1,000      NOK 1,000
(up to)

Fees of the Central Administrative Agent and Domiciliary and Corporate Agent / Fees of the
Depositary and Paying Agent / Fees of the Prime Brokers

The Central Administrative Agent and Domiciliary and Corporate Agent, Depositary and Paying
Agent is entitled to receive out of the assets of the Sub-Fund a fee calculated in accordance with
customary banking practice in Luxembourg and payable monthly in arrears. This fee will be borne
up to 0.07% p.a. of the Sub-Fund's Net Asset Value by the Sub-Fund and the amount of such fee
exceeding 0.07% p.a. of the Sub-Fund's Net Asset Value will be borne by the AIFM (i.e. Keel) or
any other entity linked to the AIFM’s group of companies.

In addition to the above fee, the Central Administrative Agent and Domiciliary and Corporate
Agent, Depositary and Paying Agent is entitled to be reimbursed by the Sub-Fund for its reasonable
out of pocket expenses and disbursements as well as for the charges of any correspondents. These
expenses, disbursements and charges will be reimbursed up to 0.07% p.a. of the Sub-Fund's Net
Asset Value by the Sub-Fund and the amount of such expenses, disbursements and charges
exceeding 0.07% p.a. of the Sub-Fund's Net Asset Value will be reimbursed by the AIFM (i.e. Keel)
or any other entity linked to the AIFM’s group of companies.

The Prime Brokers appointed in relation to the Sub-Fund do not charge any fee for the services
provided to the Sub-Fund but will be remunerated through commissions on stocks bought and sold
on the Sub-Fund’s behalf. Notwithstanding the foregoing, the Sub-Fund could be charged certain
costs related to transactions entered into by a Prime Broker for the Sub-Fund.

Management Fee / Performance Fee
Expressed in percentage of the relevant Gross Asset Value per Share (for the purpose of this sub-
section, “Gross Asset Value” shall be understood as referring to the sum of the Net Asset Value and
the Performance Fee)

Class                 EUR(C) H-SEK(C) H-USD(C1              H-USD(C2)       H-NOK(C)
Management Fee        1.5%   1.5%     1.5%                  1.5%            1.5%
Performance Fee       20%    20%      20%                   20%             20%

The Management Fee will be accrued and payable monthly in arrears to the AIFM.

The Performance Fee, if any, shall crystallise and be paid yearly at the end (the “Crystallisation
Date”) of each financial year (the ”Reference Period”) in arrears to the AIFM.
The Performance Fee is subject to equalisation, meaning that it will be accrued in relation to each
Series of Shares within each Class separately, thus ensuring that Shareholders do not pay for the
performance realised by the Class of the Sub-Fund in which they subscribe prior to their
subscription of Shares.

If, on a Valuation Day, the Gross Asset Value per Share of a Series exceeds, net of costs and
before deduction of the accrued Performance Fee, the highest Net Asset Value per Share of the

same Series reached on any Valuation Day and for which a Performance Fee was crystallised and
paid (the High Watermark), the AIFM will accrue a Performance Fee equal to 20% of the excess
performance, calculated net of costs and before deduction of the accrued Performance Fee, above
the High Watermark. The first High Watermark is the Subscription Price applied to relevant
Series. The performance reference period is equal to the whole life of the Sub-Fund.

Any Performance Fee, once paid, is not subject to being returned to the Sub-Fund, irrespective of
subsequent losses.

Foghorn X2 Fund
Subscription Fee / Redemption Fee / Conversion Fee
(Expressed in percentage of the relevant Initial Subscription Price / Net Asset Value per Share)

Class          EUR(C)         H-SEK(C)       H-USD(C)       H-USD(C2)      H-NOK(C)
Subscription   None           None           None           None           None
Fee
Redemption     None           None           None           None           None
Fee
Conversion     EUR 100        SEK 1,000      USD 100        USD 100        NOK 1,000
Fee (up to)

Fees of the Central Administrative Agent and Domiciliary and Corporate Agent / Fees of the
Depositary and Paying Agent / Fees of the Prime Brokers

The Central Administrative Agent and Domiciliary and Corporate Agent, Depositary and Paying
Agent is entitled to receive out of the assets of the Sub-Fund a fee calculated in accordance with
customary banking practice in Luxembourg and payable monthly in arrears. This fee will be borne
up to 0.07% p.a. of the Sub-Fund's Net Asset Value by the Sub-Fund and the amount of such fee
exceeding 0.07% p.a. of the Sub-Fund's Net Asset Value will be borne by the AIFM (i.e. Keel) or
any other entity linked to the AIFM’s group of companies.

In addition to the above fee, the Central Administrative Agent and Domiciliary and Corporate
Agent, Depositary and Paying Agent is entitled to be reimbursed by the Sub-Fund for its reasonable
out of pocket expenses and disbursements as well as for the charges of any correspondents. These
expenses, disbursements and charges will be reimbursed up to 0.07% p.a. of the Sub-Fund's Net
Asset Value by the Sub-Fund and the amount of such expenses, disbursements and charges
...

Item 7.        Types of Clients
As mentioned in Item 4, Keel provides investment advisory services on a discretionary basis to three
private funds, each of which is offered to U.S. investors in reliance on the exemption from
registration contained in Section 3(c)(7) of the Investment Company Act of 1940, which requires
the Sub-Funds to be offered on a private placement basis only to "qualified purchasers", as that term
is defined in the 40 Act.

In addition, Keel provides investment advisory services on a discretionary basis to a U.S. and non-
U.S. SMAs. SMA clients are typically limited to institutions and other professional investors.

With respect to the private funds, this Brochure is qualified in its entirety by the respective product’s
offering memorandum, operating or limited partnership agreement, prospectus, statement of
additional information, or similar disclosure and governing documents.