Xantos Labs LLC

ITEM 5: FEES AND COMPENSATION

The Firm's Advisory fees are set forth in the Investor Advisory Agreement. The fees are not
negotiable and lower fees for comparable services may be available from other sources.

The Firm charges a “wrap” fee which allows clients to pay a single fee for investment advisory
services (the “Wrap Program Fee”), as described below. The Wrap Program Fee is not based
upon transactions in a client account, but rather is a bundled fee, which includes the costs for
advisory services, execution, clearance, custody, and account reporting.

The Firm charges a Wrap Program Fee of the greater of a fixed $5 (flat fee) or 200 basis points
(2.00%) per year (asset-based fee), charged monthly. Asset-based fees are prorated and
charged monthly, in arrears, based upon the market value of the average daily account balance
of the securities portfolio over the preceding month. Wrap Program Fees are payable
regardless of profitability and may be charged during periods of loss. The Firm may from time
to time, in its sole discretion, offer lower fees through promotions, referrals and other discounts
to some clients that differ from the Wrap Program Fee stated above.

The Wrap Program Fee includes most trade charges applicable to an account. However, certain
other fees are not included in the Wrap Program Fee and are paid for separately by the client.

Client accounts managed by Xantos bear the following expenses:

 1. ​ Transaction costs (ACH, wire, or other transfer fees), paper statement fees, returned
 ACH or bank check fees, account transfer fees, margin interest charges, and other services.

 2. ​ In connection with specific transactions, certain professional fees for independent
 accountants, attorneys, or other experts or consultants (note that Xantos pays certain
 operating costs, including, e.g., those incurred with respect to auditing financial statements,
 and preparing tax returns, as well as professional fees of attorneys unrelated to specific
 transactions and, if applicable, corporate services provider fees);

 3.    extraordinary expenses (e.g., litigation costs and indemnification obligations), if any; and

 4.    taxes and fees payable to governmental agencies or authorities.

 5.    legal, bookkeeping, accounting, administration, auditing, tax preparation, insurance, and
 related charges;

No supervised person(s) at the Firm accepts compensation for the sale of securities or other
investment products, including asset-based sales charges or service fees from the sale of
mutual funds. For additional information on the Firm’s brokerage practices, refer to Item 12.

In the event the advisory agreement is terminated, the fee for the final billing period is prorated
through the effective date of the termination and the outstanding or unearned portion of the fee
is charged or refunded to the client, as appropriate.

As described above, a portion of the Wrap Program Fee is used to cover the securities
brokerage commissions attributed to the management of Clients’ XMA. The number of
transactions made in Clients’ accounts, as well as the commissions charged for each
transaction, determines the relative cost of the Program versus paying for execution on a
per-transaction basis and paying a separate fee for advisory services. Services provided
through the Firm’s Program may cost Clients more or less than purchasing advisory and

execution (brokerage) services separately. The Firm’s Wrap Program Fee may also be higher or
lower than fees charged by other wrap sponsors of comparable investment advisory programs.
Since the Firm pays the transaction charges in the Client’s account, there is a financial
incentive for the Firm not to place transactions in the Client’s account, to place fewer trades, or
to trade less frequently. A wrap fee account may not be in the best interest of a Client with
minimal or no trading activity as compared to a non-wrap fee account or brokerage account
where the Client would otherwise pay trading costs as incurred but a lower fee in a non-wrap
account or no advisory fee in a brokerage account. In that case, Clients would not receive the
services provided by the Firm, which are designed, among other things, to determine which
investments are appropriate for the portfolio and the Client’s account. The Firm’s decision to
trade or rebalance a portfolio will largely be guided by its process, which is driven by both
proprietary qualitative and quantitative methods. Aside from covering most of the Client’s fees
to our broker-dealer and transaction costs, fees associated with the Program include access to
our proprietary investment strategies and in-house research and therefore are higher than a
typical advisory fee for a mutual fund, traditional ETF, or similar advisory product. The Firm
believes its Wrap Program Fee is reasonable considering the quality and scope of the services
it provides and the fees charged by other investment advisers offering similar
services/programs.

The Firm in its sole discretion may from time to time offer lower fees through promotions,
referrals and other discounts to some accounts that differ from the Wrap Program Fee stated
above. Conversely, from time to time, the Firm may in its sole discretion also raise its Wrap
Program Fee. Any such program or initiative may be expanded, narrowed, suspended,
canceled, or modified at any time by the Firm in its sole discretion. To the extent any such
program or initiative is canceled or terminated, Clients will once again be charged the
then-current Wrap Program Fee on a going-forward basis. The Firm shall have sole discretion in
determining whether or not any existing Client or potential Client meets the requirements to
participate in and/or benefit from any such program or initiative, and The Firm shall not be
liable to the Client or any other party in connection with any such decision and/or in connection
with the administration of any such program or initiative generally.
...

ITEM 7: TYPES OF CLIENTS

The Firm offers services to individuals, pension and profit-sharing plans, trusts,
foundations, estates, charitable organizations, corporations, business entities,
endowments, other US and non-US institutions and entities. As set forth above in Item 4:
Advisory Business, Xantos' clients include the Accounts.

  Accounts                 Minimum Initial Investment              Minimum Investment
                                                                   Required to Maintain
                                                                   Account

  Individual               $500                                    $500, as applicable, or
                                                                   such lesser amount as
                                                                   Xantos or its principals
                                                                   may permit

  All others               $500,000                                $500,000, as applicable,
                                                                   or such lesser amount as
                                                                   Xantos or its principals
                                                                   may permit

The firm may, in its sole discretion, negotiate or waive these minimums from the range set forth
above based upon certain criteria, such as anticipated future earning, capacity, anticipated
future additional assets, the dollar amount of assets to be managed, related accounts, account
composition, pre-existing/legacy client relationship, account retention, and pro bono activities.