Swisspartners Advisors AG

Item 5 – Fees and Compensation
SPA typically offers discretionary asset management services against payment of an asset-based management
fee, which is calculated as a percentage of assets under management (“Marginal Rate”), as outlined in the table
below. The minimum quarterly charge is CHF 3,000 to cover the costs of the mandate. When a “Marginal Rate”
is agreed, each asset tier is assessed a fee percentage according to the “Management Fee Schedule” below.
The cumulative fee percentage for the Account shall therefore be determined based on a tiered approach so
that different fee percentages are applied to each asset tier according to the Marginal Rate schedule. For
example, if the assets under management for a Multi-Asset strategy amount to 12,500,000 CHF, the first
5,000,000 CHF will be subject to a 0.95% rate; the second 5,000,000 CHF to a 0.85% rate; and the residual
2,500,000 CHF to a 0.75% rate.
Management Fee Schedule as from January 1, 2020:

 Assets under management                   Marginal Rate

 in CHF or equivalent                      Multi-Asset *              Equity

 0-5M                                      0.95%                      1.05%

 5-10M                                     0.85%                      0.95%

 10-20M                                    0.75%                      0.85%

 20-50M                                    0.65%                      0.75%

 50M and higher                            negotiable                 negotiable

* Mandates that include various asset classes (i.e. “Global Defensive”, “Global Conservative”, “Global Balanced” and “Global Dynamic”)

Unless otherwise agreed in writing, existing clients who entered into a relationship with SPA before January 1,
2020 remain subject to the previous Management Fee Schedule as originally agreed before 2020. Any changes
to existing fee arrangements must be agreed in writing between SPA and its clients in accordance with the
terms of the Agreement. No fee adjustment will be made during any period for the appreciation or
depreciation of Account asset values during that period. This means that if during a quarter the value of the
assets in a Client’s Account moves into, or falls out of, a specific asset tier (see the Fee schedule above) because

© 2026 swisspartners Advisors Ltd. All rights reserved.                                                                      6 / 24

swisspartners Advisors Ltd.                                                                    Form ADV Part 2A

of market performance or cashflows, the marginal rate applicable at the beginning of the period will be applied
for that period.
Alternatively to a “Marginal Rate” fee, SPA can offer services for a “Fixed” fee, where a single specific rate or
amount is charged, irrespective of the asset tier.
As shown in the table above, SPA charges different fee rates based not only on the amount of assets under
management but also on the asset classes invested in the client’s Account. Specifically, higher fees are charged
for pure “Equity” mandates than for “Multi-Asset” manadates. This creates a conflict of interest, as there is an
economic incentive for SPA and for some of its professionals to encourage clients to increase their assets or to
recommend Equity strategies. SPA manages this conflict of interest through its compliance policies and
procedures, ensuring SPA and its Supervised Persons will always act in the clients’ best interest and not
recommend any investment strategy (or change to any strategy) unless this is in the best interest, without any
regard to the financial interest of SPA. The best interest is established in writing by the Client and SPA based
on the Client’s objectives, risk tolerance, as well as knowledge and experience in the investment services and
categories offered by SPA.
Householding fees can be offered either upon Client’s request or at SPA’s discretion. It is essential to note that
there is no obligation for SPA to agree to householding fees, and that the decision to implement such fees is
subject to mutual agreement, which must be reflected in writing in the Agreement. The eligibility criteria for
householding fees typically, but not necessarily, involve family members. Nevertheless, the eligibility critieria
can extend beyond this criterion, and decisions will be made based on the specific circumstances and
agreements between SPA and the Client.
Upon Clients’ request, and although unsolicited, SPA also offers performance-based fees, in light of which the
Clients are charged, in addition to a fixed base asset management fee, a performance-based fee, provided that
the performance is positive over the quarter. See Item 6 below for more details on performance-based fees.
Asset-based fees, fixed fees and performance-based fees (hereafter, “Fees”) are agreed in writing in the
Agreement, calculated in Swiss Francs (“CHF”), and charged in the Client's reference currency. Fees are payable
on the first business day of each calendar quarter, in advance, based on the fair market value of the assets
under management – as calculated by the custodian banks in the Client’s Account statements – on the last
business day of the previous quarter. This does not apply when a fixed Fee has been agreed with the Client
irrespective of the asset tier. If the Client’s reference currency is not CHF, SPA applies the middle-of-the day
rates of the last business day in Zurich of the previous quarter as published by SIX Financial Information (a
Swiss financial data provider and a business unit of the SIX Group). Pursuant to a Service Level Agreement
between SPA and SPG, SPG calculates the Fees based on the portfolio valuations calculated by the custodian
banks and provided to SPG by SPA. Once calculated by SPG, the Fees’ accuracy is reviewed by the Head
Portfolio Management (“Head PM”) of SPA. SPA will then send the Fees’ invoice to the client and to the
respective custodian.
...

Item 7 – Types of Clients
As mentioned in Item 4, we provide discretionary asset management services to several types of Clients,
including individuals, high net worth individuals, corporations, trusts, foundations and insurance companies.
We actively target Clients that are U.S. residents, regardless of their nationality. However, we also reserve the
right to serve clients residing outside the U.S., including Clients in the Canadian province of British Columbia
who are Canadian “permitted clients”, as defined under National Instrument 31-103 of Canada.
Although we can make exceptions to provide services for lower investment amounts, SPA believes that a
minimum amount of USD 2,000,000 typically permits adequate diversification of a Client’s portfolio. SPA

© 2026 swisspartners Advisors Ltd. All rights reserved.                                                   8 / 24

swisspartners Advisors Ltd.                                                                         Form ADV Part 2A

reserves the right to enter into Agreements with Clients that have different Account sizes. A minimum quarterly
fee of CHF 3,000 is charged to enable SPA to cover the costs of the mandate.
SPA is obliged to classify every Client as a “retail client”, “professional client” or “institutional client”, as defined
under FinSA. The extent of investor protection and suitability varies depending on the Client segment and the
types of services offered. If a Client is classified as a “professional client”, SPA assumes that the Client has the
necessary knowledge and experience, and that the financial risks associated with the advisor’s investment
decisions are bearable for the client. Clients will be informed about their classification in the Agreement.
High net worth retail Clients may declare in writing that they wish to be treated as professional clients (opting
out) when signing the Agreement or thereafter. For this purpose, high net worth retail Clients are all persons
that credibly declare either (a) to have at their disposal assets of at least CHF 2’000’000 or (b) to have the
necessary knowledge (on the basis of training, education and professional experience or comparable
experience in the financial sector) to understand the risks associated with the investments and have at their
disposal at least CHF 500’000. Conversely, institutional clients and professional clients may declare that they
only wish to be treated, respectively, as professional clients and retail clients (opting-in). All such declarations
are to be made to SPA in writing. SPA may only carry out the reclassification if the above requirements are
met. It should also be noted that a change in classification also entails a change in the level of protection
provided for and applicable under law. Clients acknowledge the associated change in the level of protection to
which they are entitled, which always relates to the entirety of asset management services.
The assets under management and number of clients of each type is shown on our Form ADV Part 1. The actual
mix of types of Clients will change over time based on market conditions, business plans, and other factors.