Newground Social Investment SPC

Item 5 | Fees and Compensation
Newground is a fee-only Registered Investment Advisor (“RIA").

The fee schedules below represent the total of management fees charged by Newground to
clients. Where beneficial, Newground will engage sub-advisors on a client’s behalf. Fees
charged by a sub-advisor are in addition to Newground’s management fees.

Fee Schedules

Newground offers two fee schedules, depending on the value of assets under management.

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ADV Part 2A                                                                                               Page 4 of 10

Fee Schedules (ver. FS25.3.11)

1. For client relationships3 over $1 million:

Account fees are computed using the following tiered pricing schedule:

         0.30% on the amount above:                                      $50 million
         0.45% on the amount between:                           $35 million - $50 million
         0.60% on the amount between:                           $10 million - $35 million
         0.75% on the amount between:                             $5 million - $10 million
         0.90% on the amount between:                             $3 million - $5 million
         1.00% on the first:                                             $3 million

         Annual rates, billed quarterly in advance

For larger accounts, Newground will generally recommend engaging separate account
managers as sub-advisors to directly manage portions of the overall portfolio, using individual
securities instead of mutual funds or exchange traded funds (“ETFs"). These sub-advisors
provide valuable expertise and capabilities – typically: (a) with greater tax efficiency, (b)
with customization, and (c) at lower cost than commensurate ETF or mutual fund alternatives.

Fees for separate account managers are in addition to the advisory fee schedules noted here.
Current sub-advisor fee rates are provided to clients prior to engagement. These rates have
historically been substantially lower than the internal operating expenses of the ETF or mutual
fund alternatives that would otherwise be used.

These rates are substantially lower than the internal operating expenses of the ETF or mutual
funds that would otherwise be used.

2. For client relationships under $1 million:

Account fees are computed using the following tiered pricing schedule:

         1.10% on the amount between:                                $750k - $1 million
         1.20% on the first:                                              $750k

         Annual rates, billed quarterly in advance

Advisory fees will be calculated according to the fee schedule above that corresponds to a
client’s overall assets under management. The determination of appropriate schedule,
whether (1) or (2), will be evaluated quarterly roughly two weeks before the end of each
calendar quarter.

Newground’s fee schedule can change from time-to-time; however, no existing client’s fee
schedule will be increased without client’s prior knowledge and consent. At the sole discretion
of Newground, fees are negotiable.

3   A ‘client relationship’ includes the value of all managed accounts considered together, such that every account
    benefits from the same economies of scale.

ADV Part 2A                                                                          Page 5 of 10

Billing & Payment of Fees, Termination

Fees are billed from client accounts on a calendar quarter basis, in advance. Unless provided
with an ADV Part 2 or other Disclosure document 48 hours prior to signing an Advisory
Agreement, a Client shall have five business days following signing during which an
Agreement can be terminated without penalty. Written fee invoices are available to all
clients upon request. Invoices will include the fee, the formula used to calculate the fee, the
fee calculation itself, the time period covered by the fee, the amount of assets under
management on which the fee was based, and the name of the custodian.

If a relationship is terminated, client is obligated for payment of services performed prior to
the effective date of termination but will receive a pro-rated refund of any fees not earned.

Other Fees or Expenses

Sub-advisors. In certain instances, we recommend that sub-advisors be engaged for the
direct management of a portion of client accounts. Recommended sub-advisors provide
valuable expertise and capabilities, typically at much lower cost than a commensurate ETF or
mutual fund alternative. Clients may engage sub-advisors independently, though generally at
a higher cost and with larger minimum investment thresholds than when engaged through
Newground.

Recommended sub-advisors contract with Newground directly to provide sub-advisory
services to clients. Sub-advisory fees are separate from and in addition to the advisory fees
paid to Newground. Prior to investment, Clients are provided the Form ADV Part 2A (or
similar disclosure) for any sub-advisor recommended, which provides complete detail on the
sub-advisory fees, billing schedule, and payment procedures. Client may elect not to use a
recommended sub-advisor.

When a sub-advisor is engaged, Newground continues to serve as a client’s primary advisor.
In this capacity, Newground remains responsible for the ongoing monitoring of sub-advisor
managed accounts as well as for whether the sub-advisor remains suitable in the context of a
client’s overall investment program. The sub-advisor is responsible for discretionary portfolio
management and trading functions related to the designated assets. Newground will
recommend adjustments to sub-advisor engagements and allocations when we believe such
changes would be in a client’s best interest.

Client-restricted assets. For specialized assets or circumstances – including low-cost-basis
stocks, illiquid investments, cash reserves, and investments held outside of Newground-
...

Item 7 | Types of Clients
Newground provides portfolio management services to individuals, businesses, corporate
pension and profit-sharing plans, charitable institutions, foundations, endowments, trust
programs, and other U.S. institutions.

Newground clients typically hold $1.5 million or more in investable assets.

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