Stratton Capital Investment Advisory LLC

Item 5 – Fees and Compensation

The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.

A. Fees for Advisory Services
Investment management fees are paid quarterly, in arrears of each calendar quarter, pursuant to the terms of the
agreement. The balance in the client’s account on the last day of the billing period is used to determine the
market value of the assets upon which the advisory fee is based. Investment management fees range from
0.01% to 1.50% annually based on several factors, including: the complexity of the services to be provided, the
level of assets to be managed, and the overall relationship with the Advisor. Relationships with multiple
objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher
fee.

The investment management fee in the first quarter of service is prorated from the inception date of the
account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The
Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities
held in accounts managed by Stratton Capital will be independently valued by the Custodian. Stratton Capital will
not have the authority or responsibility to value portfolio securities.

The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and
expenses, which may be incurred by the Client. However, the Advisor shall not receive any portion of these
commissions, fees, and costs.

B. Fee Billing
Investment management fees are calculated by the Advisor and deducted from the Client’s account[s] at the
Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s]. The amount due is calculated by applying the pro-rata rate to the total assets under
management at the end of each day. Clients will be provided with a monthly statement from the Custodian
reflecting deduction of the investment management fee. In addition, the Advisor will provide the Client a report
itemizing the fee, including the calculation period covered by the fee, the account value and the methodology
used to calculate the fee. Clients provide written authorization permitting fees to be deducted directly from their
account[s] held by the Custodian as part of the investment management agreement and separate account forms
provided by the Custodian.

                                         Stratton Capital Investment Advisory LLC
                                               430 Park Avenue NY, NY 10022
                                                 | Phone: + 1 (212) 849-1773

C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Stratton Capital, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian. The fees charged by Stratton Capital are separate and distinct from
these custody and execution fees.

In addition, all fees paid to Stratton Capital for investment management services are separate and distinct from
the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses
are described in each fund’s prospectus. These fees and expenses will generally be used to pay management
fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting),
and a possible distribution fee. A Client may be able to invest in these products directly, without the services of
Stratton Capital, but would not receive the services provided by Stratton Capital which are designed, among
other things, to assist the Client in determining which products or services are most appropriate for each Client’s
financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and
the fees charged by Stratton Capital to fully understand the total fees to be paid. Please refer to Item 12 –
Brokerage Practices for additional information.

D. Advance Payment of Fees and Termination
Either party may terminate the investment management agreement, at any time, by providing advance written
notice to the other party. The Client may also terminate the investment management agreement within five (5)
business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will
incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and
payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment management
fees from the effective date of termination to the end of the quarter. The Client’s investment management
agreement with the Advisor is non-transferable without the Client’s prior consent.

E. Compensation for Sales of Securities
Stratton Capital does not buy or sell securities to earn commissions and does not receive any compensation for
securities transactions in any Client account, other than the investment management fees noted above.

Item 7 – Types of Clients

investment management services to individuals, high net worth individuals, trusts, and estates. The Advisor
serves Clients that are primarily outside the United States. Stratton Capital generally does not impose a
minimum relationship size.