Zafiro Capital SARL

Item 5: Fees and Compensation

Management Fees

The Firm charges each Client a management fee. For the Funds, these fees are based on the
Net Asset Value (“NAV”) of each class within the Funds and are deducted from the
portfolio on a monthly basis. For the Accounts, fees charged are based on a percentage of
the monthly average net asset value of the account over the quarter (adjusted for cash
flows).

The management fees charged for the Funds varies between share classes. A summary of the
current fee schedule is set out below:

    Fund                                                  Fee range

    Unregulated funds
    Share Class A                                         2%
    Share Class A (>$20m year 1 investment)               1.75%

    Share Class B (12 month lock)                         1.5%
    Share Class B (>$20m year 1 investment)               1.25%

As determined on a case by case basis, certain Clients may receive reduced fees or a partial
rebate of their fees.

Management fees charged to the Accounts are generally based on a fixed percentage of
assets managed. This percentage will depend on the client type, the strategy and the size of
the mandate.

Our current fee schedule for individual Accounts is as follows:

    Portfolio size                                  Fee range

    n/a – no managed account clients                n/a

Fees are payable in arrears and are charged only in respect of the period for which the fund
or account was managed.

Other fees

Other fees that may be charged to the Funds are set out below:

Administrator fees
Fees are charged on a sliding scale depending on the amount of assets managed. The
administrator will also be reimbursed any reasonable out-of-pocket expenses or costs
necessarily incurred in the performance of its duties.

Prime broker and custodian fees
Prime broker and custodian fees will not exceed normal commercial rates. They may also
levy transaction charges and other charges which can include Value Added Tax.

Zafiro Capital Sarl                                                      Form ADV Part 2A

Other fees and expenses
Other fees and expenses charged may include the following:

    (a) investment-related travel expenses (which are travel expenses related to the
    purchase, sale or transmittal of the Master Fund's investments incurred by the Manager
    or the Investment Manager)
    (b) professional fees (including expenses of consultants, investment bankers, attorneys,
    accountants and other experts) relating to investments
    (c) fees and expenses relating to software tools, programs or other technology utilised
    in managing the Fund and the Master Fund (including third party software licensing,
    implementation, data management and recovery services and custom development
    costs)
    (d) research and market data (including any computer hardware and connectivity
    hardware (e.g., telephone and fibre optic lines) incorporated into the cost of obtaining
    such research and market data); administrative expenses (including fees and expenses of
    the Administrator and other similar service providers);
    (e) legal expenses; external accounting and valuation expenses (including the cost of
    accounting software packages); audit and tax preparation expenses;
    (f) fees of the Directors
    (g) costs relating to directors' and officers' liability insurance
    (h) costs of printing and mailing reports and notices
    (i) entity-level taxes
    (j) corporate licensing
    (k) regulatory expenses (including filing fees)
    (l) listing fees
    (m) organisational expenses;
    (n) expenses incurred in connection with the offering and sale of the Shares and other
    similar expenses related to the Fund; indemnification expenses; and extraordinary
    expenses.

Please see the section on “Brokerage practices” for a description of other brokerage
charges.

In the case of the Accounts only additional custody fees are applicable which are paid
directly to the applicable custodian under the contract signed directly between the Account
holder and the custodian.

Item 7: Types of Clients

Funds

The Funds managed by the Firm are described above under “Advisory Business”.

Each Fund where the Firm acts as investment adviser specifies minimum subscription limits
and the subscription and redemption terms applicable. These may vary according to the sub
fund and base currency of each individual share class. Minimum subscription limits and
redemption terms by Fund are as follows:

Zafiro Capital Commodities Trading Fund
The Zafiro Capital Commodities Trading Fund (the “Feeder Fund” is a Cayman Islands
domiciled unregulated collective investment scheme which invest all, or substantially all, if its
assets in the Zafiro Capital Commodities Trading Master Fund. The investment limit for the
Feeder Fund is US$1m although, subject to the discretion of the fund directors, smaller
subscriptions may be accepted though in any event they will be no lower than US$ 100,000.

Investors may subscribe on the first business day of each month. Subsequent redemptions
may be made on the last business day of each month provided 15 day’s notice has been given
to the fund administrator. Investors will have no right to redeem all, or any portion, of its B
Shares prior to the last day of the month occurring one year after the date such Shares were
acquired.

Zafiro Capital Commodities Trading Master Fund
The Zafiro Capital Commodities Trading Master Fund is a Cayman Islands domiciled
unregulated collective investment scheme. It does not accept any direct investments; all
investments must be made in the Feeder Fund.

Zafiro Capital Sarl                                                         Form ADV Part 2A

Accounts
The Firm may provide investment advisory services to individual Accounts. Minimum
Accounts are generally US $20m although lower Account sizes may be accepted at the
Firm’s discretion.