ZWJ Investment Counsel Inc

ITEM 5 - FEES AND COMPENSATION

ZWJ charges a management fee for its investment advisory services based on the market value of
client assets under our management. The standard fee schedule for our investment management
services is as follows:
                        1% on first $1,000,000
                       .75% on next $2,000,000
                       .50% on next $7,000,000
                       Negotiable on amounts in excess of $10,000,000
Fees may differ depending on the individual client or account circumstances; for example, certain
non-discretionary assets and accounts may be excluded from fee calculations. Also, in some cases
the fee range may be based on the account’s asset type. The fee schedule for our consulting
arrangements and reporting of private placements is customized based on the assets we are
monitoring, and the scope of services provided.

ZWJ’s management fees are billed quarterly in advance based upon the market value of the assets
at the end of the preceding quarter. For new accounts, fees are based on a pro rata calculation based
on ninety days in the billing cycle. Clients agree to our fee schedule as part of our written client
agreement, which may be terminated by either party at any time with thirty days’ written notice. In
the event of termination, ZWJ will refund to the client any prepaid, unearned portion of the
management fee based on the pro-rata effective termination date and the actual number of days in
the billing period.

Our clients have the option to pay our fees to us directly upon receipt of our invoice or authorize
the account custodian to directly debit our fee from the client account. If the client chooses the
latter method, the account custodian will not confirm our fee but will pay ZWJ a fee from the client
account based on the fee amount that we communicate to the custodian. Clients receive an invoice
each quarter for our services as part of their ZWJ account statement. Clients also receive a separate
statement from the account custodian that shows the amount of the fee sent to us and should
confirm the accuracy of our fee calculation.

Our management fees do not include brokerage commissions or other fees, or charges associated
with securities transactions implemented with or through a brokerage firm such as mark-ups or
mark-downs in principal transactions, deferred sales charges, stock exchange fees, wire transfer or
related processing fees, transfer taxes or other charges mandated by law or regulation. We do not
receive any portion of any of the foregoing expenses or fees. More information regarding how we
select or recommend brokerage firms for securities transactions in client accounts can be found in
the Brokerage Practices section of this brochure. Also not included in our fees are those fees and
expenses related to mutual funds and exchange traded funds. Information regarding these separate
fees and expenses are described in each fund’s prospectus.

As discussed in the section on Advisory Business in this brochure, some of our clients are retained
under a wrap fee arrangement with Envestnet, where clients pay an agreed upon fee for our
investment management services, brokerage commissions, custodial services, and possibly

consulting services. We receive a portion of the wrap fee charged by the brokerage firm for our
services. Our portion of the fee generally ranges from 0.15% to 0.70% of the assets managed by us
depending upon our arrangement with the wrap fee sponsor.

When ZWJ serves as investment advisor to clients of a dual contract relationship, it contracts
separately with each participating client and generally provides the same record-keeping and
reporting services as it provides to non-dual contract clients. In such cases, ZWJ’s fee is paid directly
by the client or authorized by the client for payment directly from the client’s custodial account.
The management fee is based on the market value of the client’s assets under ZWJ’s management.

Clients should be aware that other firms, including other investment management firms, may
charge a higher or lower fee for similar or comparable services.

ITEM 7 - TYPES OF CLIENTS

Our clients include individual persons, pension and profit-sharing plans, trusts, estates, charitable
organizations, and corporations or similar business entities. Generally, our minimum account size
is $1,000,000 although this may be waived based on other considerations such as the account’s
relationship to established clients or other factors.

ZWJ serves as investment adviser under certain dual contract relationships. These relationships
involve other non-affiliated investment advisers that seek specific portfolio management services
for a client relationship. These dual contract relationships have a minimum account size based on
limits imposed by the primary account investment adviser and the acceptance of ZWJ.