Sevenoneseven Capital Management Ltd

Fees and Compensation - Item 5

Portfolio Management Services Fees
For portfolio management services, Faithward Capital charges a maximum annual fee of 1.75% of the assets under
management. Fees are payable monthly or quarterly, in advance or in arrears, and are based on the value of assets
on the last day of the relevant pay period. Where the fee is payable in advance, fees will be

Faithward Capital
Form ADV Part 2A

pro-rated for the first partial month or quarter. Portfolio management fees are negotiable depending on factors such
as the amount of assets under management, range of investments, and complexity of the client’s financial
circumstances, among others. The agreed upon fee to be paid by the client will be clearly stated in an Advisory
Agreement signed by the client and the firm.

Generally, the custodian holding the client’s account will deduct Faithward Capital’s fees and any other custodial
fees directly from a designated account to facilitate billing, provided the client has given written authorization. The
qualified custodian will send an account statement at least quarterly. This statement will detail all account activity.
In the case of aggregated accounts, fees are usually deducted from a single designated client account to facilitate
billing. In limited circumstances, at the sole discretion of Faithward Capital, we may negotiate other fee payment
arrangements.

Our annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other related costs
and expenses which will be incurred by the client. However, we will not receive any portion of the commissions,
fees, and costs charged by broker dealers and custodians for accounts managed by Faithward Capital. Please see

Types of Clients - Item 7

We also act as a sub-adviser or portfolio model provider to investment advisers, and other financial institutions and
their clients including, individuals, pension and profit sharing plans, trusts, estates, charitable organizations,
corporations, and other business entities. Additionally, we act as a sub-adviser to exchange traded funds (ETFs),
which are registered investment companies. We do not require a minimum dollar amount to open and maintain an
advisory account; however, we have the right to terminate your Account if it falls below a minimum size, which, in
our sole opinion, is too small to effectively manage.

                         Methods of Analysis, Investment Strategies and Risk of Loss - Item 8

Faithward Capital advisors will use various methods to determine an appropriate investment strategy. We seek to
recommend investment strategies or products that will give you a diversified portfolio consistent with your
investment objective. We do this by analyzing the various products, investment strategies, and money management
firms to which we provide access. That analysis includes a review of the structure, cost, and investment performance
history of each program.

Faithward Capital
Form ADV Part 2A

We may use one or more of the following methods of analysis and/or investment strategies when providing
investment advice to you:

      Fundamental Analysis – Involves analyzing individual companies and their industry groups, such as a
       company’s financial statements, details regarding the company’s product line, the experience and expertise
       of the company’s management, and the outlook for the company’s industry. The resulting data is used to
       measure the true value of the company’s stock compared to the current market value. The primary risk of
       fundamental analysis is that information obtained may be incorrect and the analysis may not provide an
       accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly
       to new information, utilizing fundamental analysis may not result in favorable performance.

      Technical Analysis – Technical analysis is a technique that relies on the assumption that current market data
       (such as charts of price, volume, and open interest) can help predict future market trends, at least in the
       short term. It assumes that market psychology influences trading and can predict when stocks will rise or
       fall. Technical trading models are mathematically driven based upon historical data and trends of domestic
       and foreign market trading activity, including various industry and sector trading statistics within such
       markets. Technical trading models, through mathematical algorithms, attempt to identify when markets are
       likely to increase or decrease and identify appropriate entry and exit points. The primary risk of technical
       trading models is that historical trends and past performance cannot predict future trends, and there is no
       assurance that the mathematical algorithms employed are designed properly, updated with new data, and
       can accurately predict future market, industry, and sector performance.

      Charting – Charting is the set of techniques used in technical analysis in which charts are used to plot price
       movements, volume, settlement prices, open interest, and other indicators, in order to anticipate future
       price movements. Users of these techniques, called chartists, believe that past trends in these indicators
       can be used to extrapolate future trends.

      Cyclical Analysis – Cyclical analysis is similar to technical analysis in that it involves the analysis of market
       conditions at a macro (entire market/economy) or micro (company specific) level, rather than the overall
       fundamental analysis of the health of the particular company. The primary risks with cyclical analysis are
       similar to those of technical analysis.

We may use one or more of the following investment strategies when advising you on investments:

      Long-Term Purchases – Securities purchased with the expectation that the value of those securities will
       grow over a relatively long period of time, generally greater than one year. Using a long-term purchase
       strategy generally assumes the financial markets will go up in the long-term which may not be the case.
       There is also the risk that the segment of the market that you are invested in or perhaps just your particular
       investment will go down over time even if the overall financial markets advance. Purchasing investments
       long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term
       in other investments.

      Short-Term Purchases – Securities purchased with the expectation that they will be sold within a relatively

Faithward Capital
Form ADV Part 2A

         short period of time, generally less than one year, to take advantage of the securities' short-term price
         fluctuations. Using a short-term purchase strategy generally assumes that we can predict how financial
         markets will perform in the short-term which may be very difficult and will incur a disproportionately higher
         amount of transaction costs compared to long-term trading. There are many factors that can affect financial
         market performance in the short-term (such as short-term interest rate changes, cyclical earnings
         announcements, etc.) but may have a smaller impact over longer periods of times.

      Trading - Trading involves purchasing securities with the idea of selling them relatively quickly. We may use
       this strategy to take advantage of our predictions of brief price swings. A trading strategy creates the
...