van Cleef Asset Management Inc

Item 5 – Fees and Compensation

Our investment advisory services are provided on a fee only basis.

Van Cleef charges investment advisory fees based upon a percentage of assets under management. The
market value of assets under management is determined as of the last business day of each quarter. Our fee
schedule is then applied to the market value of assets under management. The resulting amount, divided by
four, is the amount due for the prior quarterly period. Investment advisory fees are generally charged quarterly
in arrears. If a client terminates investment advisory service during a quarterly period, the client will receive a
pro-rated invoice for the time the account was managed prior to termination. (If any client is billed in advance,
the client will receive a pro-rated refund for the unmanaged period of time.) Investment advisory agreements
may be terminated at any time, by either the client or by Van Cleef, with thirty (30) days written notice.

The annual fee schedule for investment advisory services provided by Van Cleef is noted below:

                         Market Value                                      Annual Fee
                         1st$500,000                                           1.0%
                        Next $500,000                                          0.8%
                       Balance of Assets                                       0.6%

Alternative fee schedules may be appropriate for large portfolios or low-cost basis holdings.

Advisory fees and other expenses reduce the investment return realized by clients. The reduction to
investment returns will vary depending on the specific fee schedule. A typical account with a market value of
$1 million at the end of a quarter would generate advisory fees of 0.225% or $2,250 for that quarter. Over a
one-year period the total fee will equal the sum of 0.225% of the ending market value for each quarterly period
added together. The quarterly rate annualized equals 0.90% per year. Over a five-year period, total fees would
equal 4.5% of the ending market value if such market value remained unchanged.

Clients may choose to be billed for investment advisory fees or to have investment advisory fees paid directly
from their custodial account.

From time to time, Van Cleef may invest client assets in mutual funds and/or exchange-traded funds (ETFs).
Van Cleef charges investment advisory fees on assets invested in such securities. This will result in a
client paying an advisory fee to both Van Cleef, for investment advisory services, and to the mutual or
exchange traded fund for fund advisory costs. Such fees are fully disclosed in the fund prospectus.

Investment advisory fees charged by Van Cleef do not include the following:

            •   Trade commissions paid to brokers
            •   Transaction fees
            •   SEC fees
            •   Other related costs or expenses

Clients may be charged fees by custodians, brokers, consultants and other third parties including, but not
limited to:

           •   Custodial fees
           •   Deferred sales charges
           •   Odd-lot differentials
           •   Transfer taxes
           •   Wire transfers or electronic fund fees
           •   Other brokerage fees and taxes on brokerage accounts and securities transactions.

Please see Item 12 for more information regarding how Van Cleef selects broker/dealers for client
transactions.

Item 7 – Types of Clients

A majority of our clients represent individual and family relationships, including both taxable and non-taxable
portfolios. Our firm also manages a limited number of institutional, retirement and foundation/endowment
portfolios.