Shuttleworth & Company

Item 5: Fees and Compensation

Fee Schedule

Annual fees for investment management services are calculated using a tiered billing system, based
upon the market value of the account. The fee is the sum of the results from applying the following
annual rates:

                                               Lower Range          Upper Range           Rate
      Assets Under Management                             0           1,000,000         1.00%
      Assets Under Management                     1,000,001           4,000,000         0.75%
      Assets Under Management                     4,000,001          10,000,000         0.65%
      Assets Under Management                    10,000,001          And above       Negotiable

This is a blended fee. This means that the assets in a client’s account will be billed at different
levels according to the fee schedule above. Each asset tier shall be assessed a fee percentage in
accordance with the schedule shown above. The cumulative fee percentage for the account shall
be a blended rate based on the fee percentages applied to each asset tier.

For example, if a client had an account value of $3,000,000, the following equation would be used
to calculate their quarterly fee: ($1,000,000 x 1.00%) + ($2,000,000 x 0.75%) = $10,000 + 15,000
= $25,000 annual fee / 4 quarters = $6,250 quarterly fee.

Clients are offered the choice of being billed or consenting to a direct fee withdrawal from their
account. If you choose to have the investment advisory fees deducted from your account, you must
authorize the qualified custodian(s) of your account to deduct fees from your account and pay such
fees directly to SCO. If you choose to pay the fees after receiving a statement, fees are due upon
your receipt of a billing notice sent directly to you. The billing notice will detail the assets under
management and the time period covered. Fees for our firm's services are due immediately after
receiving the billing notice.

The annual minimum fee is $1,000. This is generally charged regardless of account size but is
subject to the discretion of the management of SCO for each account and may be negotiated.

Fees are payable quarterly in arrears based upon the beginning market value of the account at each
billing period. The fee structure may differ based upon factors such as account size, cash flow,
related accounts, investment limitations, and other special requests. Additionally, SCO reserves

the right to customize fees concurrent with specific and unique advice if the client and advisor
believe it is in the best interest of both parties.

Clients also can hire SCO to manage their held-away accounts, including Employer Sponsored
Retirement Plan accounts (401k, 403b, 457, etc.) and college savings accounts (529
plans). Management services by SCO of held away accounts are offered under a separate
management fee schedule. Currently, the annual fee for the management of college saving plans
and some legacy employer sponsored retirement plans are a flat annual fee in the range of $500-
$1,000. Most accounts held away from SCO require the use of a third-party platform to avoid
having custody of Client funds. If a third-party platform is deemed necessary by SCO when
managing the held away assets, the annual fee will be 0.50% in place of the annual flat fee of $500-
$1,000.

When SCO is engaged for this type of management service, an Employer Sponsored Retirement
Account Supplement Investment Management and Advisory Agreement is signed by the client
which states the fee amount for this service. In certain circumstances mutual fund investments are
used. Clients invested in mutual funds pay an additional investment management fee to the mutual
fund advisor. Each investment advisory contract may be terminated by either party prior to its
stated expiration date, if any, upon 30 days written notice to the other. Any earned portion of
SCO’s fees not previously billed will be billed to the client on a prorated basis upon such early
termination.

No compensation arrangements are permissible with outside parties for the management or
employees of SCO.

As stated above, SCO offers discretionary management services for accounts held away from SCO
via a third-party platform to facilitate management of these assets. The platform allows SCO to
avoid being considered to have custody of client funds since we do not have direct access to client
log-in credentials to affect trades. We are not affiliated with the platform in any way and receive
no compensation from them for using their platform. A link will be provided to the client allowing
them to connect an account(s) to the platform to assist SCO to view and manage the account(s).
Client agrees to promptly address any requests to update its login credentials when requested by
the third-party system. Once client account(s) are connected to the platform, SCO will review the
current account allocations. When deemed necessary, SCO may rebalance the account considering
client investment goals and risk tolerance, current allocations and current economic and market
trends.

When clients utilize the third-party platform for discretionary management of their held away
accounts, SCO charges an annual fee of 0.50%, billed and payable quarterly in arrears, based on
the account value at the beginning of the quarter. SCO does not charge the client for use of the
platform. The Advisory Fee payable for any accounts on this third-party platform will be deducted

directly from another Client account or invoiced to the Client as agreed upon by SCO and Client
in advance.

If the held away accounts at the third-party custodian are transferred to SCO, this separate
management fee will be terminated, and the assets will fall under the current management fee
schedule of SCO, as disclosed above. Client may cancel the use of the third-party platform at any
time through the third-party. The client agrees to compensate SCO through the effective
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Item 7: Types of Clients
SCO offers investment advisory services to individuals, high net worth individuals, pension and
profit-sharing plans, and non-profit companies domiciled in the United States. The percentage of
each type of client can be found on the Form ADV Part 1A, Section 5 at
https://adviserinfo.sec.gov/firm/summary/ 121382. These percentages are subject to change and
are updated at least annually by the Advisor.

Minimum Investment Amounts Required
There are no minimum investment amounts or conditions required for establishing an account
managed by SCO. However, there is a minimum annual fee of $1,000, which is subject to the
discretion of the management of SCO for each account and may be negotiated.

All clients are required to execute an investment management agreement for services to establish
a client arrangement with SCO.