Pandi LLC

Item 5 Fees and Compensation

Our Firm charges a fee (“Advisory Fees”) as compensation for performing certain services including
advisory services, trade entry, investment supervision, and other account maintenance activities. All
advisory fees are negotiable. Our unaffiliated custodian(s) charges transaction costs, custodial fees,
redemption fees, retirement plan and administrative fees or commissions. See Other Fees and Expenses
below for details.

Pandi charges Advisory Fees that are either hourly or fixed based on the terms in the investment
management agreement.

Hourly Fees

Hourly fees are billed monthly or quarterly, in arrears, based on an hourly rate (“Hourly Rate”), for time
and services rendered. Fees may vary based on the size of the account, complexity of the portfolio, extent
of activity in the account, or other reasons agreed upon by us and you as the Client. When determining an
Hourly Rate with respect to each individual client, the specific fee, which is based on the rate payable to,
or received by, the Adviser is generally set forth in the Client’s invoice.

Fixed Fees

Fixed fees are billed in advance, based on a flat fixed rate and frequency, as agreed upon in the investment
management agreement. In certain circumstances, the fixed fees may be billed in arrears, or by other
methods, rather than in advance. You should expect that the fees you pay will differ from those paid by
other clients of the Firm, including based on the scope and size of relationships and accounts, the complexity
of the client’s needs, and other factors. Except as otherwise stated herein or in the investment management
agreement, these fees are in addition to any fees you pay to other investment managers or fees you pay
indirectly as an investor in any mutual fund, alternative investment fund, or other pooled vehicle or financial
product, which are described in the applicable prospectus or other offering document.

Sub-Advisor Fees and Services

When Pandi recommends a Sub-Adviser to manage a Client’s portfolio, the Sub-Advisor manages the assets
based upon the parameters provided by our Firm. The Sub-Advisor for the portfolio may have higher or
lower fees than other programs available through Pandi or available elsewhere. Investment management
programs typically differ in the services provided and method or type of management offered, and each
may have different account minimums. Client reports will depend upon the management program selected.
Sub-Advisor fees will be indicated on a Client’s agreement with the Sub-Advisor and will be in addition to
any fees charged by Pandi for its services.

Mutual Fund and ETF Fees

Brokerage fees and/or transaction ticket fees charged by the custodian will be billed directly to the Client.
Pandi does not receive any portion of such fees from the custodian or Client. In addition, Clients incur

certain charges imposed by third parties other than Pandi in connection with investments made through the
account, including but not limited to, mutual fund sales loads, 12(b)-1 fees and surrender charges, IRA and
qualified retirement plan fees. Pandi does not receive any portion of such fees. Management fees charged
by Pandi are separate and distinct from the fees and expenses charged by investment company securities
that are recommended to Clients. A description of these fees and expenses are available in each investment
company security’s prospectus and are paid by the funds but are ultimately borne by Clients as shareholders
in the funds.

These fees and expenses are in addition to the Advisory Fees each advisory account pays to Pandi and any
applicable transaction fees. Broker-dealers make available mutual fund share classes on their platforms at
their sole discretion. Different mutual funds with similar investment policies, and different share classes
within those funds, will have different expense levels. Generally, a fund or share class with a lower
minimum investment requirement has higher expenses, and therefore a lower return, than a fund or share
class with a higher minimum investment requirement. The share classes made available by various broker-
dealers and which Pandi selects for advisory accounts will not necessarily be the lowest cost share classes
for which Clients might be eligible or that might otherwise be available if Clients invested in mutual funds
through another firm or through the mutual funds directly. If mutual funds are selected for inclusion in the
Client’s account, those mutual funds are either no-load funds or load-waived mutual funds.

Private Fund and Alternative Investment Managers Associated Fees

As described in Item 4, Pandi could recommend that a Client invest a portion of their assets in a private
fund, hedge fund, or other alternative investment, based on the individual Client’s risk tolerance and
objectives. Important disclosures related to investing in alternative investments are described in Pandi’s
Part 2A Brochure Disclosure, Item 8 Methods of Analysis, Investment Strategies, & Risk of Loss section or
a similar agreement. Actual fees are disclosed in the private placement memorandum (PPM), a supplement
to the PPM or in a prospectus of the alternative investment fund.

Pandi does not exercise discretion over any non-public alternative investments. Clients are responsible for
initially executing any documents required to be completed by the investment manager and for continuously
maintaining any subsequent documentation required after the initial investment is made. Please see Item 4.

Other Fees

In addition to the fees described above, Clients bear other costs associated with investments or accounts
including but not limited to: (i) custodial charges, brokerage fees, commissions and related costs; (ii)
interest expenses; (iii) taxes, duties and other governmental charges; (iv) transfer and registration fees or
similar expenses; (v) costs associated with foreign exchange transactions; (vi) other portfolio expenses; and
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Item 7 Types of Clients

As discussed in Item 4 – Advisory Business of this Brochure, Pandi currently provides investment advisory
services to families, individuals, trusts, and institutions, including private foundations and private
companies owned and controlled by its family clients. We do not require a minimum dollar amount to open
and maintain an advisory account. While there is no formal minimum, certain investment strategies or Sub-
Advisers may require minimum investments. All Clients are required to execute an agreement for services.
The agreement sets forth the scope of engagement and terms and conditions of the investment management
services, outlines the responsibilities of the parties and defines the relationship of the Firm and the Client.
Lastly, the Firm will seek to obtain, verify, and record information that identifies each Client who retains
Pandi to manage its account, in order to help the U.S. Government fight the funding of terrorism and money
laundering activities.