Validus Growth Investors LLC

Item 5. Fees and Compensation

 Separately Managed Accounts

 Private Clients

 The fee rates for private clients are as follows:

                                AUM                      Fees                 Optional Performance-Based Fee
   Separate Account         Less than $1m               1.25%            OR         0.70% Base Fee PLUS
     Management                                                                20% of gains in excess of annual
                            $1m or greater            Negotiated                           hurdle

Institutional Investors

 The fee rates for institutional investors for separately managed accounts by strategy are as follows,
 subject to a minimum annual fee of $100,000:

                        Global         International          Rising           All-Cap           Small Cap
                        Growth            Growth             Dividend          Growth             Growth
  1st $25 million       65 bps            70 bps              45 bps           40 bps             60 bps
  AUM
  Next $25           55 bps                  60 bps             40 bps          35 bps             50 bps
  million AUM
  Next $50           45 bps                  50 bps             35 bps          30 bps             40 bps
  million AUM
  Above $100      Negotiable            Negotiable          Negotiable        Negotiable        Negotiable
  million AUM
 AUM = assets under management                bps = basis points

 Billing

 Validex generally deducts fees from separately managed client accounts in arrears on a quarterly
 basis based upon the average daily balance of the account assets during the period. If an eligible
 Client elects a performance-based fee, it is calculated on an annual basis as a share of gains in excess
 of an annual hurdle as agreed with the Client. Clients may also elect to be billed directly. When
 Validex allocates a SMA client’s portfolio into the DMA Fund, Validex will receive compensation as
 sub- adviser to the DMA Fund but will exclude those assets from the investment advisory fee
 charged to the client.

 A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30-
 day written notice. In the event of a new account opening or termination intra-period, fees will be
  Form ADV Part 2A                                                                                          7

 Validex Global Investing
calculated on a pro-rata basis using the average daily value of assets under management during the
shortened period.

Other Expenses and Additional Costs

Other services providers are compensated for providing services for your account. The Custodian
and Broker-Dealer, among others, will charge fees for providing account services such as custody,
margin interest, taxes, transactions, and trading. Clients are billed separately for all custody and
transaction costs. In addition, Validex utilizes ETFs and/or mutual funds to implement its portfolios,
especially with respect to asset allocation strategies. These ETFs and mutual funds have their own
internal management fees and trading costs.

Asset Allocation Services
Asset allocation services are billed according to the fee schedule for Separately Managed Accounts,
Private Clients.

Model Portfolio, Portfolio Advisory
We provide model portfolio management and portfolio services according to a negotiated fee
schedule with program sponsors based on assets under management or based upon a negotiated
fixed fee and timing as agreed upon in the client agreement.

Sub-Adviser to an Investment Company

Validex is paid an annual fee of 0.675% based on the amount of assets held in the DMA Fund. This
is subject to a cap based on the expense ratio of the DMA Fund. The annual fee is paid monthly in
arrears based on the daily net assets of the DMA Fund. Validex believes that its fees are competitive
with those fees charged by other investment advisers for comparable services. However, Validex’s
fees may be higher or lower than fees charged by other investment advisers. In addition to Validex’s
management fee, shareholders will pay other annual fund operating expenses such as shareholder
servicing fees, acquired fund fees and expenses, and certain other fees (“Net Annual Fund Operating
Expenses”).

When Validex allocates an SMA client’s portfolio into the DMA Fund, Validex will receive
compensation as sub-adviser to the DMA Fund but will exclude those assets from the investment
advisory fee charged to the client.

As we have selected Interactive Brokers to serve as broker of the DMA Fund, they are responsible
for executing securities transactions. As broker, Interactive Brokers receives commissions for its
services. We do not lower or offset our management fee by the amount of compensation received by
Interactive Brokers.

 Form ADV Part 2A                                                                                 8

 Validex Global Investing
Research Services

Research services are provided typically on a fixed fee basis as negotiated and agreed upon in the
client agreements.

Other Business
Other business services such as non-advisory research as it relates to investment operations
methodology, design and implementation are typically provided based upon a negotiated retainer
for services.

Item 7. Types of Clients
Validex offers separate account investment management services for private and institutional clients,
including public and private pension plans, endowments and foundations, independent RIAs, and
family offices. Validex's minimum account size for separate account management is $1,000,000;
however, Validex reserves the right to accept smaller accounts at its discretion.

Validex also offers model portfolio advisory services to certain investment advisory firms,
investment companies and investment programs, including Unified Managed Accounts (UMA).
Minimum investment amounts are established in the model portfolio advisor agreement between
us and the program sponsor.

Validex also acts as the sub-adviser to the Destra Multi-Alternative Fund, a closed-end management
investment company registered under the Investment Company Act of 1940.

Validex provides research services or intellectual property to institutional clients, including public
and private pension plans, endowments and foundations, independent RIAs public and private
pension plans, family offices and private portfolio companies.