Wright Investors Service Inc

ITEM 5 – FEES AND COMPENSATION

Publication Fees: Clients may receive access to Wright’s company reports and
publications as part of their negotiated contract. Subscribers who are not investment
advisory clients are charged $7,500-$15,000 annually, depending upon the range of
company reports and publications they access. All publication subscription fees are paid
quarterly in advance. The termination terms and provisions may vary depending on the
agreement, however, Wright will refund any prepaid fees allocable to the period after the
date of termination.

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Advisory Service Fees: All fees are negotiable and may be billed in advance or arrears.
Investors with related accounts will not be billed on the aggregate assets under
management. However, in general, Wright’s fees are as follows:

   a. For Institutional Clients:

                                           Fee Schedule
                                      Institutional Accounts
                         Amount                           Maximum Annual Rate
                     First $5,000,000                           0.70%
                     Next $5,000,000                            0.60%
                    Next $10,000,000                            0.50%
                    Next $15,000,000                            0.40%
                    Next $15,000,000                            0.35%
                    Next $50,000,000                            0.30%
                    Over $100,000,000                           0.25%
                                   Minimum Annual Fee: $10,000

           Minimum Account Size for International Individual Securities: $10,000,000

   b. For Sub-Advisory Clients Billed on a Relationship Basis:

                                         Fee Schedule
                       Sub-Advisory Clients Billed on a Relationship Basis
                         Amount                           Maximum Annual Rate
                     First $25,000,000                            0.35%
                    Next $25,000,000                              0.30%
                    Next $50,000,000                              0.25%
                    Next $150,000,000                             0.20%
                    Over $250,000,000                           Negotiable

            The fund sponsors may charge additional fees which are described in the fee
                               table of the applicable prospectus.

   c. For Sub-Advisory Clients Billed on an Account-by-Account Basis

                                          Fee Schedule
                   Sub-Advisory Clients Billed on an Account-by-Account Basis
                         Amount                          Maximum Annual Rate
                     First $1,000,000                            0.35%
                     Over $1,000,000                             0.25%

            The fund sponsors may charge additional fees which are described in the fee
                               table of the applicable prospectus.

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Clients who elect to utilize the tax-loss harvesting service provided by the Sub-Adviser
will pay a separate fee for this service. The Sub-Adviser charges a fee of 0.40% annually
based on the assets in the account utilizing the service. This fee is separate from and in
addition to any advisory fee charged by Wright. The Sub-Adviser’s fee is paid directly to
the Sub-Adviser by the client’s custodian pursuant to the client’s authorization. Wright
and its investment adviser representatives do not receive any portion of the Sub-
Adviser’s fee. Clients should understand that the use of the Sub-Adviser will increase the
overall cost of advisory services. Clients are under no obligation to use the tax-loss
harvesting service.

Wright provides investment services to bank trust departments, pension and profit-
sharing plans, other fiduciary institutions, and other institutional clients, which typically
include negotiated fee schedules. However, Wright may agree to a fixed fee rate with
certain clients. Fees may be modified, reduced, or eliminated where portfolios contain a
mix of investment funds and separate securities.

The specific manner in which fees are charged by Wright is established in each client’s
written agreement with Wright. Fees for investment management services are generally
based upon the market value of each account at the end of the prior billing period. These
fees are generally charged in advance pro rata to the end of the initial quarter at the time
of deposit(s); thereafter, fees are typically charged quarterly in advance. Clients may elect
to be billed directly for fees, or Wright may bill the custodian for services to be paid at
the direction of the Client. Wright will refund any prepaid fees allocable to the period
after the date of termination. The advisory agreement may be terminated by either party
by written notice to the other party as set forth in the applicable advisory agreements.

Additional deposits during the billing quarter: Wright does not charge additional fees for
deposits made to an existing account during the quarter unless the deposit is used to fund
the initial account opening. Deposits made during a quarter for an existing account are
billed in the following quarter unless the fee on such deposit amount for the remainder
of the quarter is greater than $500, in which case such pro-rated fee will be billed in the
current quarter.

Withdrawals to an account during the billing quarter: There will be no credits issued in
the quarter in which a withdrawal is made to an existing account unless the fee on such
withdrawal amount for the withdrawal is greater than $500. Assets withdrawn during a
quarter are prorated based on the number of days remaining in the quarter for unearned
...

ITEM 7 – TYPES OF CLIENTS

Wright serves many types of clients, including banks, investment companies, pension
and profit-sharing plans, individuals, corporations, and other business entities, as well
as trusts, estates, charitable organizations, and other investment advisers.