Pioneer Administrative Services Ltd

Item 5 – Fees and Compensation

   A. Fees

      PASL charges its clients an advisory fee for services provided. Each client has a written
      investment advisory agreement specifying the exact amount fees and the manner in

   which they will be charged. The advisory fee is expressed as a percentage of assets under
   care by PASL.

   The standard advisory fee is 1% per annum for discretionary and non-discretionary
   accounts.

   Generally, fees are calculated quarterly based on the daily average market value of all
   assets, including cash and the client’s loan balances, held within the client's accounts.
   However, for some accounts, the fee calculation is based on the average of the AUM at
   the beginning of the quarter and the value at the end of each month during that quarter.
   The advisory services commence on the date on which the advisory agreement is signed
   by us. The client will be charged a pro rata fee in the event the client's service is
   terminated on a day other than the last business day of the calendar quarter. In that
   event, the pro rata fee will be due and payable upon termination of the service.

   Lower advisory fees may be negotiated on an individual account basis and PASL retains
   the discretion to negotiate alternative fees on a client-by-client basis. When determining
   a negotiated fee schedule, PASL will consider client circumstances, portfolio complexity,
   anticipated future additional assets, and related accounts. As a result, clients with similar
   assets may have differing fee schedules and pay different fees. All management fees may
   be amended by PASL upon thirty days’ written notice to the client. The client may be
   charged a pro rata fee in the event the client's service is terminated on a day other than
   the last business day of the calendar quarter. In that event, the pro rata fee will be due
   and payable upon termination of the service.

   The advisory fee will be deducted by PASL from an account identified by the client for fee
   deduction. We collect the fees from the amount of any contribution or transfer, from
   available cash in the client's account, or by liquidating the client's assets held in the
   client's designated account in an amount equal to the fees that are due.

   LOWER FEE DISCLOSURE. Lower fees for comparable management, investment
   recommendation, consolidation, or concierge services may be available from other
   sources.

B. Other Fees

   In addition to the advisory fees charged by the Firm, clients are also responsible for any
   management fees and other fees and expenses charged by sub-advisors, custodians,
   funds (including the underlying fund’s management and performance fees, if any) and
   imposed by brokers, dealers or banks relating to the client’s account. Mutual funds and
   certain exchange-traded funds (“ETFs”) pay management fees to their investment
   advisers, which reduce their respective assets. To the extent that the client's portfolio
   has investments in mutual funds or ETFs, the client may pay two levels of advisory fees
   for the management of their assets: one directly to the Firm, and the other indirectly to
   the managers of those mutual funds and ETFs held in their portfolios. Neither the Firm

       nor any of its personnel receive any portion of the other fees charged. Where a sub-
       advisor is selected, there can be levels of advisory fee on the same asset. One is paid to
       PASL and the other to the sub-advisor. Value-added taxes may also be charged based on
       country of residence.

   C. Termination of Service

       A client may terminate the advisory services agreement with PASL for any reason upon
       thirty days’ prior written notice to PASL.

       PASL may terminate the advisory services agreement with a client upon thirty days’ prior
       written notice to the client.

Item 7 – Types of Clients

PASL offers its advisory services to individuals, high net worth individuals, trusts, estates,
charitable organizations, or corporations or other business entities domiciled or residing in the
United States or abroad.

When subscribing to the advisory services offered by PASL, generally, the minimum account value
is US$1,000,000. If the value of a client’s account declines below the minimum during the
advisory relationship, we reserve the right to require the client to deposit additional monies or
securities to bring the account value up to the minimum amount. In some special cases, account
minimums may be waived or negotiated.