NCH Capital Inc

Item 5. Fees and Compensation
Management Fees
Real Estate and Private Equity/Agribusiness Funds
Each limited partnership agreement for NCH’s real estate and private equity/agribusiness
Funds provides for payment to the Adviser of asset-based management fees for investment
management services. These fees are generally fixed at an annual rate of 2% of funded
commitments; these fees have been reduced in certain funds which are in liquidation. Such
management fees are charged in advance on a quarterly basis via a capital call notice to
Limited Partners.

On April 8, 2024, by Decree of the President of the Russian Federation, the Russian
holding companies for the business conducted by NCH Agribusiness Partners, L.P.
(“NAP”)’s portfolio company AgroTerra LLC were transferred under temporary
administration to the Russian government’s Federal Agency for State Property
Management. These assets are currently valued at zero on NAP’s balance sheet. The
Adviser continues to lobby for the termination of such temporary administration which
appears to be linked to the sanctions and countersanctions imposed by Russia and the
United States in connection with the war in Ukraine. Considering the uncertainty now
facing AgroTerra, while not required under NAP’s Limited Partnership Agreement, the
management fee charged in relation to AgroTerra has been temporarily reduced by 50%.

Equities Funds
Each limited partnership agreement for NCH Funds investing primarily in public equities
in Russia and other countries of Eastern Europe provides for payment to the Adviser of
asset-based management fees for investment management services. Such fees range from
1% to 2% of net asset value per annum and are paid quarterly in advance from Fund assets.
Due to sanctions and related trading restrictions imposed following Russia's attack on
Ukraine, management fees applicable to a Fund's Russian securities are being waived until
the General Partner determines that more normal conditions have returned to the market.
While management fees on Ukraine-related securities were also waived due to war-related
market instability, management fees applicable to selected, more liquid, Ukraine-related
securities are being reinstated as of April 1, 2026.

These Funds may hold illiquid assets that have been designated by the General Partners to
be treated as “side-pockets”, in which case, pursuant to the Funds’ respective limited
partnership agreements, management fees are generally charged based on cost at the time
of designation.

Expenses
In addition to the asset-based fees, a Fund may also bear certain expenses incurred by the
Adviser in connection with the services provided to the Fund, such as the respective
organizational, operating and other expenses of the Adviser. The most common expenses

NCH Capital Inc.
Form ADV 2A
April 30, 2026

include (i) expenses incurred in connection with identifying, evaluating, structuring and
negotiating any potential Fund investment (including broken deals) and the acquisition,
holding, sale, proposed sale or valuation of any Fund investments (including brokerage,
custody and other types of fees); and (ii) ordinary administrative expenses, fees of auditors,
attorneys, appraisers and if applicable, a Fund’s valuation agent or administrator, and other
professionals, costs of meetings, and reports to Limited Partners.

Certain Funds, pursuant to a Fund’s governing agreement, share in the allocation of NCH
operating and overhead expenses, which include, but are not limited to, compensation of
employees and consultants (excluding compensation to the Principals), benefits, and travel
and accommodations of employees of the Adviser or its affiliates, as well as overhead of
the Adviser or its affiliates allocable to a Fund, including but not limited to, office rental,
office services and equipment, telephone and utilities. Overhead is allocated to all Funds;
however, for the Private Equity Funds and a Fund in liquidation, they are allocated to and paid
by the respective General Partner entity. Below is a list of those NCH Funds that participate
in the allocation of NCH operating and overhead expenses:

            •   NCH Balkan Fund, L.P.
            •   NCH Eagle Fund, L.P.
            •   NCH Russia Fund, L.P.
            •   New Century Holdings XI, L.P.

NCH Balkan Fund L.P. and New Century Holdings XI L.P. also bear the cost of incentive
compensation to employees of the Adviser. The incentive program includes bonuses
and/or commissions paid to traders, profit sharing on investments, and/or, compensation
based on a share of distributions to the Funds from portfolio companies, and there are Funds
in which employees have a minority interest in portfolio companies.

With respect to the Funds listed above, their portfolio companies may directly compensate
employees of the Adviser when such employee performs duties for a portfolio company,
including serving as a board member or director. There is no reimbursement or offset of
management fees by the investment manager for this compensation. In some cases, an
employee may be paid partly by a Fund (and/or portfolio company) and partly by NCH.

Affiliated Service Providers
There are portfolio companies of certain NCH Funds providing services to other portfolio
companies of NCH Funds. Services include property administration services, procurement
services, grain elevator and transportation services, custodial, accounting and finance
services, rental and utilities, IT services, and credit reports. These relationships are at arm’s
length and based on market rate fees. The General Partner/Manager of a Fund providing
services to an affiliated entity does not receive a transaction fee/compensation for such
services.

In addition, there are affiliated entities that provide property management services. The
costs associated with such property management services are reimbursed by the portfolio

NCH Capital Inc.
Form ADV 2A
April 30, 2026
...

Item 7. Types of Clients
The Adviser provides investment supervisory and management services to the Funds.
Investors in the Funds are institutional and other sophisticated investors, such as university
endowments, corporate and government pension funds, family offices and high net worth
individuals. As a general policy, the Funds are offered privately only to “qualified
purchasers” as defined in the Investment Company Act of 1940, as amended (“Investment
Company Act”). All investors in the Funds must also be “accredited investors” as defined
in the rules promulgated under the Securities Act of 1933, as amended.

NCH Capital Inc.
Form ADV 2A
April 30, 2026