Needham & Company LLC

Item 5. Fees and Compensation

Needham offers Research Advisory Services to institutional investment advisers and
other fiduciaries ancillary to brokerage as part of the Firm’s own client commission
arrangements (the “CCA Program”) and as a third-party research provider in conjunction
with client commission arrangements sponsored or administered by other broker-dealers,
in accordance with Section 28(e) of the Securities Exchange Act of 1934 (the “Section
28(e) Safe Harbor”).

Research Advisory Services offered as part of Needham’s CCA Program are paid for
with commissions charged to clients of the CCA Program for brokerage transactions
effected by the Firm for such clients. The commission rate and the amount allocated for
the payment of Research Advisory Services and other third-party research are separately
negotiated with each client. A portion of the commissions charged is credited to the
client and allocated for the payment of Research Advisory Services and other third-party
research on a periodic basis.

Needham also offers Research Advisory Services as a third-party research provider in
connection with client commission arrangements of other broker-dealers. The specific
amounts paid by clients for Research Advisory Services as part of other broker-dealers’
client commission arrangements or otherwise are negotiated with the client in each
instance.

In addition, the Firm may offer Research Advisory Services independent of the CCA
Program or another broker-dealer’s client commission arrangements for a fee.

Item 6. Performance Fees and Side-by-Side Management

Needham does not provide investment supervisory services to clients or otherwise
manage investment advisory accounts. Accordingly, Needham does not have any
performance fee arrangements with clients.

Item 7. Types of Clients

Needham provides Research Advisory Services primarily to institutional investors,
including pooled investment vehicles.