Turim 21 Investimentos LTDA

Item 5. Fees and Compensation
    Management fees for accounts other than the VC Funds are calculated as a percentage of each
    client’s assets under management and are invoiced or debited to the client account either
    monthly or semiannually in arrears as per the individual client’s investment management
    agreement. Turim’s usual management fee ranges from 0.40% to 0.55%. However, exceptions
    can occur due to volume under management per client and it will then vary between 0.10% to
    0.80%. Performance fees as described below will usually range from 10% to 15%. However,
    exceptions can occur due to volume under management per client and it can range from 7.5%
    to 20%. Please refer to the investment management agreement for details regarding the
    relevant fees charged. Fees are negotiable.
    For the VC Funds, the Firm will charge an annual management fee that ranges from 0.5% to
    0.75% based on contributed capital. The fee is paid quarterly in advance. The fee will only be
    charged to investors who are not currently clients of the Firm. No management fee will be
    charged by the VC Funds to investors who are clients of the Firm (fees are charged to current
    clients at the portfolio level). For more information regarding such fees, please refer to the
    offering documents for the VC Funds.
    Performance Fees for accounts other than the VC Funds:
    In addition to management fees, clients will also pay performance fees which are charged
    semiannually in arrears as a percentage of the client’s net portfolio performance over a
    negotiated hurdle rate, subject to a high­water mark.
    In addition to the performance fees referenced above, the Firm will also charge a performance
    fee for certain private equity investments made on behalf of clients. The performance fee
    charged is subject to the following:
        1.       The performance fee is due only after the client has received distributions from the
                 investment that exceeds the sum of:
                          a. the contributed capital
                          b. the calculated hurdle rate, if applicable; and
                          c. underlying management fees paid for the investment
        2.       The performance fee for each private equity investment is calculated separately
                 without regard to the performance of any other private equity fund’s performance.
    Carried Interest for the VC Funds:
    Affiliates of the Firm will be entitled to additional compensation in the form of a carried interest
    based on certain realization events in the VC Funds. The amount of such carried interest will up
    to 16% of profits on realization events. For more information regarding such fees, please refer
    to the offering documents for the VC Funds.
    The Firm may also provide financial planning services which are included as a service as part of
    the management fees paid by the client.
    Other Fees and Expenses

Turim 21 Investimentos LTDA                                                               March 2026

    Fees Charged to clients in Addition to the Fees Listed Above:
    1. Brokerage Commissions and Other Transaction and Third­Party Fees: Clients will pay all
       brokerage commissions, custodial fees and service charges, stock transfer fees and other
       similar charges incurred in connection with transactions for the client’s account. In
       addition, the client could be subject to:
             a. Wire transfer and electronic fund fees;
             b. Fees for odd­lot differentials;
             c. Other fees and taxes related to brokerage accounts; and
             d. Other charges as required by law.
        These charges will generally be paid out of the client’s assets held with the custodian and
        are in addition to the investment advisory fee paid to the Firm. For further information
        on brokerage relationships, please refer to Item 12 of this brochure.
        For investments in mutual funds and exchange traded funds, clients could incur additional
        charges imposed by third parties, including, but not limited to, the following:
               a.     Mutual fund sales fees and sub transfer fees;
               b.     Internal management fees and administrative expenses for mutual funds and
                      exchange traded funds that are disclosed in the fund prospectus; and
               c.     Mutual fund transaction fees and mutual fund short term redemption fees, if
                      applicable.
    2. Fund Investments: Clients invested in certain VC Funds and third­party investment
       vehicles, including private funds ("Investment Funds") can expect to be charged
       management fees, performance fees and certain administrative expenses by the third­
       party Investment Fund manager. All these fees are in addition to the fees disclosed above.
       Fund management fees charged by third party Investment Fund managers generally range
       from 1% to 3% annually. Depending on the terms of each Investment Fund, performance
       fees typically range from 10% to 30% of the annual net profits, subject to certain
       limitations. All fees and administrative expenses are disclosed in the offering documents
       that clients receive for each Investment Fund. In addition, each Investment Fund requires
       clients to meet specific qualifications in order to invest.

Turim 21 Investimentos LTDA                                                                  March 2026

Item 7. Types of Clients
    Turim’s clients consist of primarily ultra­high net worth families. The Firm also advises the VC
    Funds.

Turim 21 Investimentos LTDA                                                                  March 2026