Triumph Capital Management

ITEM 5: FEES AND COMPENSATION

Investment Management Fees and Compensation

TCM charges a fee as compensation for providing investment management services on your account.
These services include advisory and consulting services, trade execution, investment supervision, and
other account maintenance activities. In addition, TCM’s custodian may charge transaction costs,

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custodial fees, redemption fees, retirement plan fees, alternative asset fees, and other administrative
fees or commissions. Please see “Additional Fees and Expenses” below for further details.

Certain assets (e.g., mutual funds, ETFs, alternative investments, UITs, MLPs, etc.) deposited or
purchased in your accounts may also be subject to separate management and administrative fees, as
described in the applicable prospectus or agreement. These fees are independent of TCM’s fees and
should be disclosed by the custodian or contained in the investment’s offering documents. Clients
should be aware that fees for comparable services vary, and lower fees may be available from other
sources.

The annual fee for portfolio management services is billed quarterly or monthly, either in arrears or in
advance. The fee is based on the average daily market value of the account(s) during the billing period,
or on the prior quarterly or monthly ending balance. Fees are calculated on a calendar-year basis
(including leap years). Because of deposits or unsettled trades, the prior quarterly or monthly ending
balance used for fee calculation may differ from the account value shown on the custodian’s statement.
Fees are assessed on all assets under management—including securities, cash, and money market
balances—unless otherwise noted in the client agreement. TCM may exclude certain positions for
billing purposes. Margin balances do not reduce the value of assets under management. For accounts
held at Charles Schwab, clients can view both average daily balances and end-of-period balances
through Black Diamond and Schwab portals.

TCM’s maximum annual investment advisory fee is 3.00%. The specific fee applicable to each client
is outlined in the investment advisory agreement. Fees may vary depending on account size, portfolio
complexity, account activity, or other factors agreed upon by TCM and the client. In some cases, fees
and billing arrangements may be negotiated. TCM also charges a minimum fee of $180 annually for
accounts held at Charles Schwab, though this fee may be waived or reduced at TCM’s discretion.

In certain cases, TCM may aggregate household account balances to determine the applicable advisory
fee. This consolidation allows clients to benefit from a higher combined asset total, which may reduce
the effective advisory fee under the applicable schedule.

The independent qualified custodian holding client assets will debit the advisory fee directly from the
account and remit payment to TCM. Clients provide written authorization permitting fees to be
deducted directly from their custodial account. Custodians provide independent account statements at
least quarterly, showing account balances, transaction history, and all fees deducted, including TCM’s
advisory fees. Clients are encouraged to carefully review these statements for accuracy. At TCM’s
discretion, advisory fees may also be paid by check. Clients with questions about their management fee
calculation or the data inputs used are encouraged to contact the TCM Compliance Department, which
will provide full details regarding fees.

Either TCM or the client may terminate the management agreement upon written notice to the other
party. Upon termination, the management fee will be prorated through the effective date of termination
for the quarter or month in which notice was given, and any unearned fees will be refunded or
additional fees billed. After termination, clients are solely responsible for monitoring and managing the
securities in their account, and TCM will have no further obligation to act on or advise regarding those
assets.

Managed by Triumph Capital Management at Security Benefits Fees

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Advisory fees for the Managed by TCM program at Security Benefit range from 1.0% to 1.5%,
depending on the Security Benefit option selected. Fees are charged quarterly in advance, based on the
prior quarter’s ending account balance. Because of deposits or unsettled trades, the balance used for fee
calculation may differ from the account value shown on the custodian’s statement. Clients can access
prior quarter account balances through their quarterly Security Benefit statement. If you have any
questions about the accuracy of your management fee or the data inputs used to calculate it, please
contact the TCM Compliance Department.

The independent qualified custodian, Security Benefit, debits advisory fees directly from your account
and remits payment to TCM. Written client authorization is required to permit these fee deductions.
Security Benefit will provide an account statement at least quarterly, showing all amounts deducted from
your account.

Security Benefit determines the values of the assets in your portfolio. In addition to advisory fees,
Security Benefit charges an annual custodial fee of 0.25%. Accounts with balances under $50,000 are
subject to an additional $35 annual fee (waived for balances of $50,000 or more). These fees are separate
from, and in addition to, the TCM advisory fee of 1.0% to 1.5%. Please review the Security Benefit
Mutual Fund Program Brochure and the applicable prospectuses for further details on fees and expenses.

In addition, securities used in the Managed by TCM program at Security Benefit (e.g., mutual funds,
ETFs, sub-accounts, etc.) may be subject to separate management and administrative fees as described in
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ITEM 7: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS

TCM provides investment advice to individuals, high-net-worth individuals, families, small businesses,
foundations, trusts, charitable organizations, and estates. We also advise on retirement accounts,
including – but not limited to – IRAs, SEPs, SIMPLEs, Solo 401(k)s, retirement trusts, defined benefit
plans, small business 401(k) plans, and corporate 401(k) plans.

TCM does not impose minimum requirements for opening or maintaining accounts, or for engaging our
services.

However, certain TPAMs may require a minimum account size, and these requirements can vary from one
TPAM to another.

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