New Vernon Investment Management LLC

FEES AND COMPENSATION

NVIM charges both asset-based “management fees” and performance-based “performance fees” to the
NVIM Funds.

With respect to its management of the Global Opportunities Funds, NVIM generally receives a quarterly
asset-based management fee equal to approximately 0.375% (approximately 1.5% per annum) of the net
asset value of the fund family. With respect to its management of the Insurance Funds, NVIM generally
receives a monthly asset-based management fee equal to approximately 0.083% (approximately 1.0% per
annum) of the net asset value of the fund family.

NVIM has in the past, and may in the future, in its sole discretion, waive or reduce the management fee
with respect to certain NVIM Funds and/or any investor in the NVIM Funds, including its affiliates or
employees. Management fees are paid by the NVIM Funds by the deduction of such fees from the funds’
assets. The performance fees paid by the NVIM Funds are described below in “Performance Based Fees.”

With respect to its management of a Client Account, NVIM may charge either or both an asset-based
“management fee” and/or a performance-based “performance fee,” which may be higher or lower than the

fees paid by the NVIM Funds. The types and amounts of fees payable in respect of a Client Account will
be set forth in an investment advisory agreement between NVIM and the applicable client and may be
negotiated based on a variety of factors, including, but not limited to, the size, composition and complexity
of the Client Account, length and nature of NVIM’s relationship with the client, special services agreed
upon with the client or other factors deemed relevant by NVIM. Additionally, in some cases, NVIM’s
affiliate, SFI, may receive rebates from Pershing, LLC for certain administrative and/or recordkeeping
services based on the average amount of Client Account cash balances invested through a money market
program as described below in “Client Referrals and Other Compensation.”

NVIM has also entered an arrangement with a third-party investment adviser pursuant to which NVIM
receives an annual fixed fee in exchange for NVIM’s dissemination of historic portfolio data relating to the
NVIM Funds. In addition, NVIM may receive a discretionary bonus calculated in the manner as such client
may determine in its sole discretion.

Other Fees and Expenses. The NVIM Funds will incur other expenses in connection with NVIM’s
advisory services. NVIM’s fees do not include transaction fees, brokerage commissions, custody fees and
other related costs and expenses that will be incurred by the NVIM Funds with respect to the transactions
for their account. The NVIM Funds will also bear the investment management or other fees charged by
any mutual funds, exchange-traded funds or collective investment vehicles in which they may invest, as
disclosed in the prospectus for the applicable fund.

Each NVIM Fund has incurred legal and organizational expenses in connection with its formation and
offering, which will be borne by the applicable NVIM Fund (and, therefore, indirectly by its investors). In
addition, the NVIM Funds will also bear ongoing expenses, which may include, without limitation, legal,
bookkeeping, accounting, auditing, recordkeeping, administration, computer and clerical expenses
(including expenses incurred in preparing reports and tax information and regulatory authorities and
expenses for specialized administrative services); filing fees; the costs of any future restructuring of such
fund and/or updates to such fund’s organizational and offering documents; printing and duplication
expenses; investment related travel expenses, investment research expenses, market data, newswire and
data processing expenses; software and connectivity charges; brokerage commissions, bank charges,
custody fees and borrowing costs; exchange, board of trade or other trading or execution facility
membership or participation expenses; reasonable costs of attending directors’ meetings; annual
registration fees; directors’ fees; directors’ and officers’ liability insurance; investment and operating
expenses; and such other expenses necessary to perform the operation of such fund. The NVIM Funds will
also be responsible for any applicable extraordinary expenses of such fund (including taxes, indemnification
costs, litigation costs, trade errors or damages).

              PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT

As compensation for its management of the Global Opportunities Funds and the Insurance Funds, NVIM
or NVP (as defined below) also will be entitled to receive a performance-based fee or allocation from each
fund family. This performance-based compensation generally is equal to 20% (with respect to the Global
Opportunities Funds) or 10% (with respect to the Insurance Funds) of the net increase in value (if any) of
each investor’s equity interest in the applicable NVIM Fund (including both realized and unrealized gains
and losses) over the applicable measurement period, after payment of the management fees described above
and recovery of losses experienced by such investment in prior measurement periods.

This performance-based compensation is calculated and payable annually as of the end of each year or upon
withdrawal by an investor of all or part of its investment in the NVIM Fund. NVIM and NVP have in the
past, and may in the future, waive, reduce or otherwise vary this compensation with respect to certain NVIM
Funds and/or any investor in the NVIM Funds, including affiliates and/or employees of NVIM or its
affiliates.

With respect to its management of a Client Account, NVIM may charge a performance-based fee in addition
to, or in lieu of, an asset-based management fee. The amount and payment terms associated with any such
fee may be subject to negotiation between NVIM and the client, as described above. See “Fees and
Compensation.”
...

TYPES OF CLIENTS

Currently, NVIM provides investment advice primarily to private investment funds operated by NVIM or
its affiliates. NVIM operates certain of the NVIM Funds in reliance upon the exclusion from the definition
of an “investment company” described in Section 3(c)(1) of the Investment Company Act of 1940, as
amended (the “1940 Act”). In order to qualify for this exclusion, investment in such NVIM Funds is
generally limited to no more than 100 U.S. persons who are “accredited investors,” as defined in Rule 501
of Regulation D under the Securities Act of 1933, as well as non-U.S. investors. In general, the definition
of “accredited investor” includes (a) individuals with either (i) $200,000 in annual income, (ii) $300,000 in
joint annual income with his/her spouse, or (iii) $1 million in net worth, excluding his/her primary residence
and certain related indebtedness; and (b) entities (i) with $5 million in assets, or (ii) which are wholly-
owned by other accredited investors.

NVIM also operates certain of the NVIM Funds in reliance upon the exclusion from the definition of an
“investment company” described in Section 3(c)(7) of the 1940 Act. In order to qualify for this exclusion,
investment in such NVIM Funds is generally limited to U.S. persons who are “qualified purchasers,” as
defined in Section 2(a)(51) of the 1940 Act, as well as non-U.S. investors. In general, the definition of
“qualified purchaser” includes individuals with $5,000,000 or more in “investments” (as defined by the
U.S. Securities and Exchange Commission (“SEC”)) and entities with $25,000,000 or more in
“investments,” as well as certain other specified categories of entities.

NVIM also provides investment advisory services to a limited number of Client Accounts. Currently,
NVIM advises one Client Account owned by a fund of funds. NVIM has also entered into a research
contribution agreement with an unaffiliated investment adviser, to whom NVIM provides certain dated
information regarding the trading and portfolio composition of certain NVIM Funds.

         METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS

NVIM Fund Strategies

Each of the NVIM Fund families has unique investment objectives and strategies, based upon the specific
investment focus of the applicable fund.

Global Opportunities. The primary investment objective of the Global Opportunities Funds is to achieve
capital appreciation through investment in a variety of securities and derivatives instruments, with a focus
on securities or derivatives related to, or believed to be affected by, global growth and emergence of middle-
class consumers in developing markets, based on NVIM’s analysis of various fundamental factors. NVIM
seeks to capture the higher returns that it believes are offered by emerging market investments, while
seeking to minimize draw-downs caused by the volatility of such investments, by implementing a “core
equity” investment process, and simultaneously employing supplemental “pairs trading” and “macro
trading” strategies in an attempt to provide additional return and enhance diversification.

Insurance. The primary investment objective of the Insurance Funds is to employ the insurance and
investment industry experience of certain of NVIM’s principals to earn superior risk-adjusted returns in
insurance and insurance-related securities. The Insurance Funds primarily focus on the U.S.
property/casualty sector within the insurance industry, but may also invest in insurance brokers and the life
and health insurance sectors. In its trading on behalf of the Insurance Funds, NVIM utilizes a value-based
fundamental approach in an effort to identify undervalued securities for investment, as well as potential
short sale candidates.

Client Account Strategies

NVIM may manage the assets of other Client Accounts pursuant to one or more of the strategies described
above, or may provide customized advisory services to such clients, as agreed between NVIM and the
applicable client. The Client Accounts currently advised by NVIM employ a modified version of the
Insurance Funds’ strategy, subject to specific guidelines agreed upon between NVIM and the clients.

Certain Risk Factors.

The identification of attractive investment opportunities is difficult and involves a significant degree of
uncertainty. Potential clients should consider the following risks before engaging NVIM to manage their
assets.

Reliance on Fundamental Analysis. NVIM may base its trading decisions, in whole or in part, on
fundamental analysis. Fundamental trading methodologies consider factors, such as inflation, trade
balances, inventories and interest rates, which do not have an impact on traditional technical trading
systems, in an attempt to identify investment opportunities. To the extent that such factors provide mixed
or conflicting signals, a fundamental trading program may not be able to detect and/or accurately predict
price trends. There can be no guarantee that NVIM’s fundamental analysis and trading methodologies will

enable NVIM to accurately value the securities and other instruments in which the NVIM Funds or Client
Accounts invest or that any anticipated price trends will materialize with respect to such investments.

Changes in Trading Approach. NVIM may not follow one specific investment strategy, but rather, may
employ different trading strategies which NVIM feels are consistent with an NVIM Fund’s or Client
Account’s investment objective. Because NVIM may change an NVIM Fund’s allocation of assets among
a variety of diverse investments and strategies at any time, investors in an NVIM Fund or Client Account
may be exposed to the risks associated with each of those investments and strategies but may not know at
the time of investment, or over the duration of their investment, the precise nature of such exposure. An
investment in an NVIM Fund or Client Account therefore may involve a high degree of uncertainty and
...