Wilen Investment Management Corp

Item 5 – Fees and Compensation

Portfolios are handled on an individual and discretionary basis. Initial positions range from
approximately 1 percent to 5 percent so that ample diversification is present in all accounts.
Our minimum account size is $250,000 and clients pay a quarterly fee in arrears based on
the net asset value at the end of each quarter. Our fee schedule as of June 1, 2012 is as
follows:

       FIRST $1,000,000                     1.5% PER ANNUM

       SECOND $1,000,000                    1.4% PER ANNUM

       THIRD $2,000,000                     1.3% PER ANNUM

       OVER $4,000,000                      1.2% PER ANNUM

Fees are not subject to negotiation.

The specific manner in which fees are charged by Wilen Investment Management Corp. is
established in a client’s written agreement with Wilen Investment Management Corp. Wilen
Investment Management Corp. will generally bill its fees on a quarterly basis. Clients are
billed in arrears each calendar quarter. Clients may also elect to be billed directly for fees or
to authorize Wilen Investment Management Corp. to directly debit fees from client accounts.
Management fees may be prorated for each capital contribution and withdrawal made
during the applicable calendar quarter depending on the timing of such activity (with the

exception of de minimis contributions and withdrawals). Accounts initiated or terminated
during a calendar quarter will be charged a prorated fee. Upon termination of any account,
any earned, unpaid fees will be due and payable.

Wilen Investment Management’s fees are exclusive of brokerage commissions, transaction
fees, and other related costs and expenses which shall be incurred by the client. Clients may
incur certain charges imposed by custodians, brokers, third party investment and other third
parties such as fees charged by managers, custodial fees, odd-lot differentials, transfer taxes,
wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
securities transactions.

Item 7 – Types of Clients

Wilen Investment Management Corp. provides portfolio management services to individuals,
high net worth individuals, corporate pension and profit-sharing plans, TaftHartley plans,
charitable institutions, foundations, endowments, private investment funds, trust programs,
and other U.S. and international institutions.