Navellier & Associates Inc

ITEM 5. FEES AND COMPENSATION

Fees are negotiable. It is the client’s responsibility to determine if the fees Navellier charges are suitable. Our fees
may be higher than other investment advisers offering similar services. Management fees are sometimes subject to
negotiation and renegotiation. Our fees cover investment advisory, including money market funds or ETFs, reporting,
and account -related services. In some cases, we may share a portion of our advisory fee with other advisers or
brokerage firms in return for client referrals. This creates a potential conflict of interest whenever we have an
opportunity to refer a potential client to an adviser or brokerage firm or receive a referral from a firm with which we
share our advisory fees. Such referrals may or may not be in the client’s best interest, and we may be biased towards
such referring or referred advisory or brokerage firms. Navellier attempts to resolve such potential conflicts of
interest by clearly disclosing the fee sharing arrangement and the potential for conflicts of interest before we open
any client account with other advisers or brokerage firms where we share any advisory fees. We provide pro-rata
refunds.

While we do not maintain physical custody of any client assets, depending on the agreement with the client, we
may be allowed to authorize the custodian to debit the client account the amount of our advisory fees and include on
the monthly statement notification of the deduction for advisory fees. You can select this method of advisory fee
payment on the Investment Advisory Agreement you sign with Navellier. If you choose to not have fees directly
deducted from your account by the custodian, we will send you a quarterly invoice. You are responsible for any
tax liabilities that result from any transactions.

You will incur brokerage and other transaction costs related to your accounts. Navellier’s fees do not cover any
execution-related expenses, commissions and margin interest, if any, securities exchange fees, or other fees required
by law or charged by the broker-dealer with custody of your account. (Please refer to Item 12, Brokerage Practices,
for further information regarding brokerage fees.) From time to time, our defensive strategy accounts may hold
significant amounts of cash, usually represented by money market fund or an ETF. We generally reduce our fees
allocable to cash held in your account more than 90 days.

Our management fees may vary from the applicable schedule below due to a particular client’s circumstances or as
otherwise negotiated with the client or its intermediaries, or in connection with our participation in a wrap fee or other
structured money management program. Our fee may vary depending on factors such as the type of client, the level
of client assets under management, and the existence of an intermediary relationship, among other things.

Similar accounts may have different fee schedules based on the historical nature of the accounts or through
negotiation with the client. From time to time, and under agreed-upon specific situations, we may reduce a
client’s advisory fee on a case-by-case basis.

Navellier generally offers two management fee options:

     1)   Fees Based on Assets Under Management: In addition to variations described in item 5 above, fees based
          on assets under management for the services provided by Navellier to the client generally range depending on
          the particular investment strategy from an annual fee of 0.30% to 1.25% of assets under management, except
          for the Navellier Private Client Group whose fee structures are different and are described more fully below.
          Fees are accrued daily and are calculated and payable in advance on a quarterly basis, unless negotiated
          otherwise. Navellier calculates fees based on the market value of the account as of the first business day of
          each calendar quarter. In the case of the first quarter under management, we calculate fees on the effective
          inception date of the account and, in the event the account becomes effective after the first day of the calendar
          quarter, fees are calculated proportionately based on the number of days remaining in the quarter. There is no
          minimum fee. If the client terminates an account before the last day of a calendar quarter, we will refund the
          client a pro-rata portion of previously paid fees based on the number of days remaining in the calendar quarter.
          Clients typically authorize the custodian to withdraw any outstanding fees owed to Navellier directly from their
          account following termination of the account.

          The portfolio value Navellier uses to calculate fees is the bank’s or securities broker’s month-end or
          quarterly statement. In the event the client’s portfolio contains securities for which no readily available
          market quotations exist, we determine the value of such securities, for purposes of fee computation, based
          on a quotation by an independent market maker or specialist for the security.

    2) Performance-Based Fees: Performance-Based fees are available to qualified clients who meet all
        requirements of the then current SEC Rule 205-3 immediately upon entering into a management agreement
        with Navellier.

          Performance-Based fees are accrued daily and payable annually beginning twelve (12) months after the
          client executes an Investment Advisory Agreement and becomes effective with respect to an account and
          annually thereafter. Navellier calculates fees, as outlined on the Investment Advisory Agreement between
          the client and Navellier, on the amount of increase, if any, in the net market value of the account in the
          preceding twelve (12) month period after deduction of all fees and commissions paid (including fees and
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ITEM 7. TYPES OF CLIENTS

Navellier may not necessarily at all times provide advisory services to the following types of clients:

     •    Individuals (other than high net worth individuals)
     •    High net worth individuals
     •    Trusts
     •    Charitable organizations and endowments
     •    Estates
     •    Professional and religious organizations

     •    Corporations
     •    Pension and profit sharing plans
     •    State or municipal government entities
     •    Taft-Hartley plans

Our minimum account size for institutional separate accounts would typically be $1,000,000. Our minimum account
size for wrap fee programs and certain financial intermediary programs varies by program. Under certain instances,
we will accept smaller account sizes or reject larger accounts.