Mavros Capital Management LLC

Item 5 - Fees and Compensation

Fees
Investment Management Fees

Except with respect to the initial quarter, Mavros’ management fees will be charged as a percentage
of assets under management, according to the following schedule:

 Billing Rate         Break Range
 1%                   $0 to $10,000,000*
 0.90%                $10,000,001 to $20,000,000
 0.80%                $20,000,001 to $30,000,000
 0.70%                $30,000,0001 and up

 * Minimum annual fee is $10,000

The fee schedule for Investment Management services is a straight tier. Mavros may negotiate
management fees based on the Client’s assets under management and the financial complexity of a
Client’s investment objectives. With respect to multiple Clients from the same family/household, or
who are otherwise related parties (e.g., employees of the same company), Mavros may aggregate
such Clients’ assets for purposes of calculating the management fee.
For example:
Household Investment Amount =$5,000,000
($5,000,000 x 1% (Investment Management Fee)) = $50,000 Annual Fee

Calculation and Payment of Fees

Management fees are based upon the total assets in the Client Account managed by Mavros. Except
with respect to the initial quarter, fees are payable quarterly in advance, using the prior quarter-end
value of the assets in the Client Account (determined as of the last business day of the prior calendar
quarter), and calculated quarterly using the actual day count methodology. A Client Account becomes
subject to Mavros’ management fee beginning the later of (i) the effective date of the IMA, or (ii) the
date the last Client’s signature executing the IMA is received (the “Management Fee Start Date”).
For the initial quarter, the management fee is payable in arrears based on the value of assets in the
Account from the Management Fee Start Date to the last day of the calendar quarter during which the
Account was initially funded, pro-rated for any partial quarter period.

Fees are also described in IMA, and we generally retain the right to amend our fee schedule with 30
days prior written notice to the client. A Client’s IMA can be terminated at any time, by either party,
for any reason upon 5 days’ written notice. If a Client has paid any management fees in advance for
the period in which their IMA is terminated, Mavros will pro-rate the management fees for the period
and return any unearned portion to the client by check or wire transfer.

Generally, Client fees will be debited from the Client’s Account that generated the fee, unless
otherwise indicated by the Client in writing. If a Client does not have enough liquidity in its Client
Account to pay the management fee, Mavros may instruct the custodian to liquidate securities in the
Client Account. The amount of the management fee will be pro-rated for periods of less than a full
billing period.

The custodian sends the client a statement, at least quarterly, indicating the amount of our fees and all
amounts disbursed from the account to Mavros for our fees. The client is responsible for verifying the
accuracy of the fee calculation, as the custodian will not verify the calculation. Only the custodians'
account statement will be sent to clients.

Mavros’ management fees are generally exclusive of fees and/or expenses charged by third parties,
including custodial fees, brokerage commissions (see Item 12 – Brokerage Practices), third-party
Investment Manager fees, mutual fund fees, odd lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Mutual funds, exchange traded funds, and private funds are subject to their own respective internal fees
and expenses, including management fees, which are disclosed in the respective investment offering
documentation. In addition, private alternative investment funds will charge performance-based fees,
and fund expenses such as audit, legal, administrative and other such fund level related expenses.
Third party management fees range from 0.10% - 1%, paid by the client. the total fees charged by
Mavros in addition to third party managers will not exceed 3% per annum. A Client can terminate
any service at any time, for any reason with written notice. Lower fees for comparable services may
be available from other sources. We deduct fees from client assets.

Mavros is deemed to be a fiduciary to advisory Clients that are employee benefit plans subject to
ERISA or plans subject to Section 4975 of the Internal Revenue Code of 1986 (the “Code”), such as
individual retirement accounts (IRAs). As such, Mavros is subject to specific duties and obligations
under ERISA and the Code that include, among other things, restrictions concerning certain forms of
compensation. To avoid engaging in prohibited transactions, Mavros will only charge fees for
investment advice on products for which Mavros does not receive any commissions or trailing fees
such as 12b-1 fees, unless such payments are structured in a manner that complies with ERISA and
the regulations and rulings of the Department of Labor, including PTE 2020 -02.

Mavros nor any of our supervised persons accept compensation for the sale of securities or other
investment products, including asset-based sales charges or services fees from the sale of mutual funds.
Mavros does not offer a wrap fee program.

Item 7 - Types of Clients

Generally, Mavros provides advisory services to single family offices, individuals, ultra-high net
worth individuals or families, retirement plans / plan sponsors, trusts, foundations, endowments, non-
profit

organizations, and other business entities.

Mavros will target working with Clients whose net worth is $10,000,000 or more. The Firm reserves
the right to accept Clients of any net worth.