Naples Global Advisors LLC

Item 5 – Fees and Compensation

The Firm's revenues are generated exclusively from advisory fees and are transparent to clients.
Advisory fees are based on a percentage of assets under management.

Separately, the custodian (Charles Schwab or Fidelity Investments) may impose certain fees
related to custodial services provided to client accounts. Such fees may be tied to security
transactions or a flat fee determined by the custodian. Additionally, the custodian may impose or
deduct other expenses or fees such as foreign security taxes, American Depositary Receipts (ADR)
fees, fees for trading certain securities or mutual funds, and charges for wire transfers, as
representative examples. Additionally, securities traded on foreign exchanges incur added
transactional expenses or brokerage commissions that will vary by custodian, country, and
exchange.

The fees paid to the Firm for advisory services are identified distinctly and are separated from
custodial charges. Custodians typically have expenses inside their money market instruments that
are reflected as a reduction of net yield. Also, other expenses and fees may be embedded inside
exchange-traded funds and mutual funds.

The Firm's typical annualized advisory fees are based on the following tiered schedule:

                    Annual Advisory Fee                   Annual Fee Percentage
                     First $2,000,000                                    1.0%
                     Next $2,000,000                                     0.8%
                     Next $1,000,000                                     0.6%
                     Next $45,000,000                                    0.5%
                     Next $50,000,000                                    0.4%
                     Amounts Above $100,000,000                          0.3%

The applicable fee schedule may differ from client to client and affiliate to affiliate, but the general
advisory structure and source of fees collected remain consistent. On rare occasions, fee schedules
may be negotiated based upon unique and extraordinary circumstances. Fees are generally
deducted directly from a client's account on a monthly basis. However, alternative arrangements
may be accommodated on a case-by-case basis.

Investment management fees are collected monthly, in arrears, at annualized rates. Each client or
aggregation of family portfolios is valued on the last business day of the month for fee calculation
purposes. Related accounts may be considered together when applying tiered pricing, often
resulting in a lower overall blended rate. In cases where an investment advisory relationship
begins after the first day of a billing period, or terminates prior to the last day, fees are prorated
for the period.

Although the Firm does not make a practice out of charging fees other than asset-based fees, the
Firm does maintain the right to charge extraordinary fees for services that are considered beyond
usual and customary. Such other matters that are not routine in the conduct of an investment
advisory relationship subject to charges may include consultation on non-investment
management matters, analysis, and advice relating to assets and holdings not managed by the
Firm.

The Firm does not sell any investment products. Therefore, the Firm and its IARs do not accept
compensation for the sale of securities or other investment products, including asset-based sales
charges or service fees from the sale of mutual funds or other securities.

The Firm does not recommend the use of margin for investment purposes. However, the Firm does
facilitate the establishment of margin features on clients’ behalf when clients direct the use of
margin for investment or non-investment access to liquidity. In any instance where margin is
activated in a client account, the Firm’s investment management fee payable will be assessed gross
of margin. This is because the nature and character of the underlying investable assets does not
change. However, with a margin balance, the market value of the client's account and
corresponding fee payable by the client to the Firm will be increased. Where investment
management fees are assessed gross of margin, a conflict of interest exists as the Firm has an
incentive to use margin to increase its fees.

When deemed to be in the client’s best interest, the Firm will recommend that clients engage the
Firm to rollover their retirement accounts or move retirement assets to the Firm’s management.
Such a recommendation creates a conflict of interest if the Firm earns a new (or increase its
current) advisory fee as a result of the transaction. No client is under any obligation to rollover a
retirement account to an account managed by the Firm.

The client agreement allows for cancellation, in writing, at any time by either the client or the Firm
for any reason. There are no termination fees; although management fees earned up to the date of
termination will be prorated and charged to the account or billed to the client.

Item 7 – Types of Clients

The Firm provides discretionary investment management services to the following types of
clients:

              -   High net worth individuals
              -   Individuals (other than high net worth)
              -   Retirement plans, principally IRAs
              -   Corporations
              -   Trustees
              -   Charitable Organizations

The targeted relationship minimum valuation is investable assets of $1 million. Family or related
accounts may be bundled together to attain the stated relationship minimum. There may be
exceptions to this guideline when there is the future opportunity to reach the threshold, when the
minimum annual advisory fee is met, or when an alternative agreement is reached with the client.