Sammons Financial Group Asset Management LLC

Item 5: Fees and Compensation

   A. Advisory Fees

      SFGAM’s advisory fees are set forth in each client’s Investment Management Agreement. Fees
      are generally negotiable and may vary based on factors such as the size of the mandate,
      investment strategy, and operational complexity. SFGAM applies its fee arrangements in a
      manner consistent with its fiduciary duty to treat clients fairly and equitably.

      Advisory fees are typically calculated as an annualized percentage of the client’s assets under
      management and are billed quarterly in arrears based on the value of assets in the account.
      Alternative fee arrangements may be negotiated at SFGAM’s discretion.

   B. Other Fees and Expenses

      In addition to SFGAM’s advisory fees, clients generally also pay, usually on a pro rata basis,
      certain other fees and expenses, including the following: Sub-Adviser fees, investment related
      expenses, whether relating to investments that are consummated or unconsummated,
      including trading costs, brokerage costs, clearing and settlement charges, interest expenses,
      research and related expenses, due diligence expenses; custodial fees; legal expenses;
      professional fees, including expenses of consultants and experts; audit and tax preparation
      costs and expenses; regulatory and filing fees; administrative fees; and litigation,
      indemnification and other extraordinary expenses.

      Some of these additional fees and expenses could be payable to SFGAM or entities affiliated
      with SFGAM as compensation for services rendered. This creates a conflict of interest, as
      SFGAM or its affiliates have a financial incentive to recommend such services. SFGAM
      addresses this through disclosure, governance oversight, and adherence to fiduciary
      obligations.

      Most fixed income instruments trade at a bid/ask spread and without an explicit brokerage
      charge. Accordingly, while there is not a formal trading expense, clients will bear the implicit
      trading costs reflected in those spreads. Please see Item 12 for further discussion of brokerage
      practices.

   C. Prepayment of Fees

      Clients may choose to pay fees in advance. In the event of account termination, fees paid in

                                                        Sammons Financial Group Asset Management, LLC
                                                                                             ADV Part 2A
       advance, if any, will be pro-rated to the date of termination and any unearned portion will be
       refunded to the client.

   D. Compensation for Sales

       Neither SFGAM nor any of its supervised persons accept compensation for the sale of securities
       or other investment products.

Item 7: Types of Clients

SFGAM currently provides advisory services exclusively to affiliated insurance companies and
reinsurance entities.

SFGAM does not impose minimum requirements for opening or maintaining an account.