Polaris Investment Partners Inc

Item 5 – Fees and Compensation

 Traditional Private Accounts

 Polaris offers independent, fee-only investment management services to individuals, families, benefit plans and
 institutions managed under our private account services. Polaris receives no commission from marketable
 securities. Fees received are based upon a client’s total assets advised in these private account services or a
 management and performance fee based upon the client’s investment in one of the Advisor’s affiliated private
 funds. If a client is invested in the Adviser’s affiliated private funds, then no Advisory Fee will be charged but
 the client will incur a management fee being an investor in a fund we manage. Advisory Fees are charged by
 Polaris as described in each client’s written agreement with the Adviser. Advisory Fees are billed quarterly in
 arrears and are usually debited by the custodian from a client’s custodial account and remitted by the custodian
 to Polaris. The quarterly fee may be adjusted for significant contributions or withdrawals that occur during the
 billing period which comprise 10% or more of the Account value.

 Polaris generally charges asset-based fees that will not exceed 1.00% per annum for advisory relationships with
 natural persons or institutions with a minimum annual fee of $1,000 per year per advised household, whichever
 is greater. In most circumstances, the actual Advisory Fee charged will depend on the total assets held in these
 traditional private account services with breakpoints at various asset levels or some clients are billed a flat
 percentage or dollar fee regardless of asset level. In most cases, as the asset level increases, the flat or graduated
 asset-based fee is reduced as a percentage of assets. The Adviser may offer discounted rates to its employees and
 their families, as well as to institutional and very high net worth clients with substantial account balances at fee
 levels that may be lower than the ranges indicated above.

 All fees and account minimums are negotiable. Fees may be waived at the sole discretion of the Adviser. All
 Advisory Fees are exclusive of brokerage commissions, transactions fees and other related fees and expenses
 which shall be incurred by the client. Mutual funds, exchange-traded funds and annuities all charge internal
 management fees and other expenses, which are disclosed in a fund prospectus or equivalent disclosure document
 and are directly deducted from the value of such investment vehicles. Such charges, fees and commissions are
 exclusive of and in addition to Polaris’ Advisory Fee. Polaris and/or its investment adviser representatives do not
 receive any portion of these commissions, fees and costs and do not have any affiliation with the sponsors or
 providers of these investment vehicles.

 Alternative Investment Strategies

 Private Funds - Investment Management & Administrative Fees: The Adviser charges its affiliated private funds
 an investment management fee based on the net asset value or as specified in the relevant special documents for
 each fund. The investment management fee is typically in the range of 0.75% to 1.5% annually. There is no
 minimum annual fee. Certain private funds are also charged a “Basic Fee” for administrative services at a rate of
 0.25% annually based on the net asset value of the fund. The Adviser deducts such fees from the private fund by
 instructing the fund’s custodian.

 To invest in private funds requires the receipt and completion of special documents in which all additional

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 expenses are delineated. Further to specifications in the relevant documents for each fund:

              The investment management and administrative fees are charged each month in arrears
               based on the total market value of the investments (including net unrealized appreciation
               or depreciation of investments and cash, cash equivalents, accrued interest, and net of
               expenses) on the last day of each month.

              An investor in a private fund will only be charged its share of the investment management
               and administrative fee for the precise months in which its assets were invested.

              The investment management and administrative fees may be reduced or waived for
               investors that are employees, relatives of employees, sub-adviser employees, and strategic
               investors. From time to time, such fees may be waived for all fund investors at the
               discretion of the general partner or the investment manager.

 Other Fees and Expenses associated with Private Funds: Private funds are also subject to other investment
 expenses such as custodial charges, brokerage fees, commissions, and administrator costs plus expenses
 including, but not limited to, sales expenses, legal expenses, internal and external accounting, audit and tax
 preparation expenses; and organizational expenses. Private fund fees and expenses are passed on to the fund
 investors. From time to time, certain of these fees may be paid by the Adviser or its affiliate at the discretion of
 same.

 Managed CTA Portfolios – Polaris offers investment management fee-only selection and monitoring of CTAs to
 qualified high-net-worth individuals, families, and institutions. Polaris receives no commission. The fees received
 are based upon a client’s total assets advised assets invested in this specific alternative investment portfolio.

 Regarding all Alternative Investment Strategies: In addition to any of the Adviser’s fees and other expenses
 discussed above, each Private Fund (and its investors) or Managed CTA Client will also bear a separate layer of
 costs which include management and incentive fees, brokerage and other transaction costs, and administrative
 expenses for any third-party manager’s fund or CTA’s portfolio in which a Polaris Private Fund or Managed CTA
...

Item 7 – Types of Clients

 Polaris offers investment solutions and counsel to wealthy families, high net worth individuals, retirement assets,
 institutions, and private funds.