Randolph Co Inc

Item 5. Fees and Compensation

Fees for investment advisory services are based on the market value of securities in accounts managed by RCO
on the last day of each calendar quarter -- March, June, September and December. The final fee for each quarter
will be prorated to reflect any deposits or withdrawals made during the quarter. Specifically, additions to or
withdrawals from the account(s) will be prorated based on the number of days remaining in the quarter from the
date of such transaction(s), and the fee will be adjusted accordingly.

RCO’s fees are calculated using the annual schedule below and are billed quarterly for the previous quarter:

       •   .90% of the first $1,000,000 (.225% quarterly)
       •   .80% of the next $1,000,000 (.20% quarterly)
       •   .65% of ALL funds thereafter (.1625% quarterly)

The minimum annual fee is $750.00 which may be waived at RCO’s discretion. Fees are automatically deducted
from accounts by the end of the months of April, July, October and January. There are no prepaid fees.

Fees for the initial quarter will be adjusted pro-rata based upon the number of calendar days in the quarter that the
agreement is in effect. Client must pay for services rendered up until the date of termination. If the agreement is
terminated prior to the end of a calendar quarter, the fee for the final quarter will be pro-rated accordingly.

RCO retains discretion to negotiate alternative fees on a client-to-client basis. The client’s annual fee will be
detailed within the Investment Advisory Agreement between each client and RCO. For example, any related
accounts constitute a “household”. All household accounts aggregating more than $3,000,000 are subject to a
negotiated fee.

There may be additional brokerage expenses relating to trades. Small incidental fees (less than .002%) may be
charged by the various exchange markets to cover the costs of supervising and regulating the markets. RCO may
invest client accounts in exchange-traded funds (“ETFs”) and/or mutual funds. These types of investments may
charge fees as disclosed in the respective fund’s prospectus. RCO does not receive a portion of these fees, nor
does it receive any other compensation for the purchase or sale of securities or other investment products.

There is a conflict of interest when an RCO employee makes a recommendation that a participant roll over assets
from a retirement account into a new or existing account (e.g., rollover IRA) managed by RCO. The conflict of
interest exists, because RCO may receive compensation (e.g., management fees) if the money is rolled over, but
RCO will not receive compensation if the recommendation is not accepted. In some cases, RCO could have
recommended that the participant leave his or her money in the plan, and, in that case, RCO would not be
compensated for their advice. RCO will manage this conflict through a process designed to develop an informed
recommendation in the best interest of the client and in accordance with new requirements set for the by the
Department of Labor (“DOL”).

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Item 7. Types of Clients

 RCO offers investment management to individuals, high net worth individuals and families, trusts, foundations
 and business entities. The required minimum balance to open an account is $1,000,000. This minimum may be
                                          waived at RCO’s discretion.