St James Investment Company LLC

Item 5 - Fees and Compensation
Clients pay St. James an annual fee for services rendered under their respective investment advisory
agreements. St. James calculates the annual fee according to the terms set forth below.

Fee Calculation
Fees are paid quarterly, in advance or in arrears according to the terms of the Investment Advisory
Agreement, based on the market value of the account on the last trading day of the previous quarter. For the
initial billing cycle, of accounts billed in advance, the fee is calculated based on the number of days the account
was managed during the quarter in which it funded, in addition to the fee for the following quarter. Fees for
partial quarters are prorated based on the number of days the client’s account was open during the quarter.
However, should an account terminate after the 15th of the last month of a quarter, the account will be billed
for the full quarter. Fees are deducted from the client’s account in accordance with this brochure and the
custodian’s account application. It is St. James’ preference to deduct the fee directly from each account, but a
client may request another method of payment. With regard to ERISA accounts, fees are deducted directly
from the Plan account.

Refunds of fees may be available upon cancellation of the Investment Advisory Agreement as herein
provided. Refund checks are issued, at the end of the quarter, to the account custodian for deposit into the
client’s account.

The fee charged, by St. James, may be higher or lower than normally charged in the industry, and it is possible
the same, similar, or significantly different services may be available from other investment advisers at higher
or lower rates. Some of the factors that determine the fee, are the type of services provided, type of account being
managed, the custodial arrangement, and the total assets under management from related accounts. St. James
allows for negotiable fees. The maximum annual fee charged by St. James is 0.75%.

Sub-Advised Accounts
St. James provides sub-advised portfolio management services for a number of independent registered
investment advisers and an investment company. For servicing these individually managed accounts, St.
James charges an annual asset management fee. St. James calculates this fee, according to the terms of the
Investment Sub-Adviser Agreement, using the process described in the “Fee Calculation” section above. St.
James debits the sub-advised client’s account directly for those fees. (In some cases, the adviser debits the
client’s account and pays St. James its portion of the fee.) Accounts are marked closed when the Adviser
confirms termination. St. James receives a maximum annual fee of 0.50% based on the assets managed. The
fee is negotiable based upon the type of services provided, type of account(s) being managed, the custodial
arrangements, the total assets under management from related accounts, and size of the assets managed on
behalf of the organization utilizing St. James as a sub- adviser. Sub-advised clients will almost always pay an
additional management fee to their primary adviser.

Model Distribution
In select circumstances, St. James distributes a model of an investment portfolio, for use by other advisers, for
an annual management fee of 0.50% of assets managed using the model.

General Information on Fees
In addition to the St. James advisory fee, clients may pay fees for custodial services, account maintenance,
transaction fees and other brokerage fees associated with maintaining an account. St. James does not share in
any portion of such fees. Please see “Item 12 – Brokerage Practices”, on page 7 of this brochure.

                                                                                       St. James Investment Company
                                                                                       The Brochure – March 2026

All fees paid to St. James for investment advisory services are separate and distinct from the fees and expenses
charged by funds to their shareholders. Clients should understand that account assets invested in shares of
mutual funds, ETFs, or other investment companies (“funds”) are subject to additional fees and expenses, as
described in the prospectuses of those funds, paid by the funds but ultimately borne by the client. These fees
will generally include a management fee, other fund expenses, and possibly a distribution fee. A client may
invest in funds directly, without the services of St. James. In that case, the client would not receive the services
provided by St. James, which are designed, among other things, to assist the client in determining which
investment strategy is most appropriate to the client’s financial situation and objectives. The client should
review both the fees charged by the funds, and the fees charged by St. James, to fully understand the total
amount of fees to be paid by the client. For purposes of calculating its advisory fee, St. James excludes client
assets that are invested in funds sub-advised by St. James.

St. James does not receive “Indirect Compensation”, which is compensation received from outside sources.

Item 7 - Types of Clients
St. James provides advisory services to private individuals, trusts and estates, an investment company,
pension, profit sharing and other retirement plans, charitable organizations, and foundations. St. James generally
requires that separately managed accounts have a minimum of $100,000 in total asset value to be managed.
Exceptions may be made in certain situations.