Alexander Capital Advisors, LLC

Alexander Capital Advisors, LLC is the sponsor and investment manager of the Alexander Capital Advisors, LLC Wrap‐Fee Program (hereinafter the "Program"). A "wrap‐fee" program is one that provides the Client with advisory and brokerage execution services for one all‐inclusive fee. Except as described below, a Program Client is not charged separate fees for the respective components of the total service. To participate in the Program, our Clients must direct the use of Schwab Advisor Services (formerly TD Ameritrade Institutional) to act as broker and custodian for Program account securities transactions. Alexander Capital Advisors, LLC provides its Clients (i.e. individuals, pension and profit‐sharing plans, trusts, and business entities) with discretionary investment management services. We do not provide financial planning or insurance planning services. To the extent specifically requested by a Client, we may provide limited consultation services on investment and non‐investment related matters. Any such consultation services, to the extent rendered, will be rendered exclusively on an unsolicited basis, for which we shall not receive any separate or additional fee. Alexander Capital Advisors, LLC provides continuous advice to a Client regarding investment of Client funds based on the individual needs of the Client. Through personal discussions in which goals and objectives based on a Client's circumstances are established, we develop a Client's suitability and risk tolerance levels, and create and manage a portfolio based on such. We will manage advisory accounts on a discretionary basis only. Account supervision is guided by the stated objectives of the Client (i.e., conservative total return, moderate total return, or aggressive total return). Alexander Capital Advisors, LLC will create a portfolio consisting of one or all the following: individual equities, bonds, ETF’s, other investment products, and no‐load or load‐waived mutual funds. We will allocate the Client's assets among various investments taking into consideration the financial objectives of the Client. The mutual funds will be selected based on any or all the following criteria: the fund's performance history; the industry sector in which the fund invests; the track record of the fund's manager; the fund's investment objectives; the fund's management style and philosophy; and the fund's management fee structure. Portfolio weighting between funds and market sectors will be determined by each Client's individual needs and circumstances as well as market conditions. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on the Client's behalf. Clients will retain individual ownership of all securities. When appropriate to the needs of the Client, Alexander Capital Advisors, LLC may recommend the use of trading (securities sold within 30 days), margin transactions or option writing. Because these investment strategies involve certain additional degrees of risk, they will only be recommended when consistent with the Client's stated tolerance for risk. The annual fee for the Program is 1.35% of assets under management. In certain circumstances, fees may be negotiable. The wrap fee includes all advisory and brokerage costs (including transaction costs), quarterly performance reports, third party custodial fees and transfer taxes. Since Thomas F. Paolozzi III is the sole portfolio manager, and the sole owner of Alexander Capital Advisors, LLC, Client’s written agreement with Alexander Capital Advisors, LLC establishes that Client accounts will be debited by the custodian in advance for the wrap fee (also known as “advisor’s fee”) on a quarterly basis as follows: January 1 for the period consisting of the first quarter, April 1 for the period consisting of the second quarter, July 1 for the period consisting of the third quarter, and October 1 for

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the period consisting of the fourth quarter. These dates may vary at the discretion of the advisor. The amount of the fee will be based upon the value of the Client’s account on the month end prior to the payable date. In considering this Program, a prospective Client should be aware that the Program may cost a Client more than purchasing the services separately from other advisors or broker‐dealers. The factors that should be considered by a prospective Client include the size of a Client’s portfolio, the nature of the investments to be managed, commission costs, custodial expenses, if any, the anticipated level of trading activity and the amount of advisory fees for only managing the Client portfolio. The Program's wrap fee does not include interest charges, electronic fund and wire transfer fees, The American Depository Receipt agency processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law. The wrap fee also does not include internal management fees and fund expenses charged by mutual funds and ETFs. Because brokerage costs associated with executing trades are included in the wrap fee, Alexander Capital Advisors, LLC pays the transaction costs associated with trading in client accounts participating in the Program. As a result, the Firm may have an incentive to limit trading activity in client accounts in order to reduce these costs. Clients should consider that, depending on the level of trading activity in their accounts, the wrap fee program may cost more or less than purchasing advisory services and brokerage services separately. Alexander Capital Advisors, LLC and its President receive compensation because of the Client’s participation in the Program as described above. We offer no alternative investment advisory or wrap program; therefore, we receive no additional compensation because of our Clients’ participation in this Program. There is no conflict of interest associated with recommending the Program to our Clients as it is the only Program available. Clients should understand that similar advisory services may be available from other state registered investment advisors for higher or lower fees.

Alexander Capital Advisors, LLC provides portfolio management services to individuals, high net worth individuals, pension and profit‐sharing plans, trusts, estates, or charitable organizations, corporations or business entities, and a private investment fund (The Plato Fund, L.P.). We require a minimum of $1,000,000 of assets under management, calculated by household, for investment supervisory services, although this may be negotiable under certain circumstances (i.e. anticipated future earning capacity, anticipated future additional assets, related accounts, account composition, etc.). Alexander Capital Advisors, LLC groups related Client accounts (households) for the purposes of achieving the minimum size requirement.

Client contact with Thomas F. Paolozzi III is not restricted in any way. Phone calls are always accepted, and face‐ to‐face meetings are encouraged on an annual basis if possible.

As previously indicated, Thomas F. Paolozzi III serves as President of Alexander Capital Advisors, LLC and manager of all Client portfolios. He is therefore privy to all significant Client information which is typically provided at the inception of the Client relationship. Client investment goals and risk tolerance are confirmed annually, and Clients are urged in writing to update us promptly if there are changes to their financial condition.

Alexander Capital Advisors, LLC is the sole investment manager for the Program and does not consider third‐party investment managers for the Program.

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Thomas F. Paolozzi III, Owner of Alexander Capital Advisors, LLC, is the sole portfolio manager of Client accounts and makes all investment decisions.

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Advisory Business See Item 4 – Advisory Business. Performance‐Based Fees and Side‐By‐Side Management Performance based fee arrangements may create an incentive for an advisor to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. Such fee arrangements also create an incentive to favor higher fee‐paying accounts over other accounts in the allocation of investment opportunities. As discussed below, Alexander Capital Advisors, LLC has procedures designed and implemented to ensure that all Clients are treated fairly and equally, and to prevent this conflict from influencing the allocation of investment opportunities among Clients. In addition to managed accounts, Alexander Capital Advisors, LLC provides investment advice to a private investment limited partnership known as The Plato Fund, L.P. (the “Fund”), for which Alexander Capital Advisors, LLC acts as the General Partner. The Fund is not available through the Wrap‐Fee Program. Alexander Capital Advisors, LLC charges all Wrap‐Fee Clients a percentage of assets under management. Partners in the Fund are charged a management fee and a performance‐based incentive fee. Given that Alexander Capital Advisors, LLC manages both types of accounts, and there is an incentive to favor those that pay a performance‐based incentive fee, this conflict of interest is addressed in the firm’s Policies and Procedures/Code of Ethics. Specifically, limitations are placed upon the timing of trades in the Fund relative to those in other Client accounts, and all trades are reviewed monthly to ensure adherence to these procedures. Methods of Analysis, Investment Strategies and Risk of Loss Alexander Capital Advisors, LLC uses various security analysis methods as the basis for its investment strategies. This information is derived from financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, annual reports, prospectuses, filings with the SEC, company press releases, as well as other various independent analyses. The investment strategies used to implement any investment advice given to Clients include, but are not limited to, long term purchases (securities held at least a year), short term purchases (securities sold within a year), and when appropriate to the needs of the Client, Alexander Capital Advisors, LLC may recommend the use of trading (securities sold within 30 days), short sales, margin transactions or option writing. Because these investment strategies involve certain additional degrees of risk, they will only be recommended when consistent with the Client’s stated tolerance for risk. Through our association with Schwab Advisor Services, Clients can and sometimes do receive institutional class funds as part of their portfolio construction. Comprehensive research, disciplined value‐based strategy, absolute return focus and low portfolio volatility frame every investment decision at Alexander Capital Advisors, LLC. We search for well‐managed companies and securities that are temporarily priced below their true longer‐term value. Securities in our portfolio share many of the following attributes:

Increasing cash flow and operating margins Attractive price to book value -7-

Increasing insider and management ownership Unique balance sheet characteristics Leadership changes among business lines within the company Known company board or management Business plans and strategies that consider equity and profitability

Alexander Capital Advisors, LLC concentrates on companies and ETFs with market capitalizations between $400 million and $4 billion. Investing in securities involves risk of loss that Clients should be prepared to bear. Voting Client Securities Alexander Capital Advisors, LLC does not vote Client proxies. Therefore, although we may provide investment advice relative to Client investment assets, our Clients maintain exclusive responsibility for (1) directing the way proxies solicited by issuers of securities beneficially owned by the Client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the Client’s investment assets. The Client shall correspondingly instruct the custodian of the assets that all proxies and shareholder communications relating to the Client’s investment assets should be sent directly to the Client from the issuer. Clients may contact us with any questions about a solicitation.

Disciplinary Information. State registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of them or the integrity of their management. Alexander Capital Advisors, LLC has no legal or disciplinary events to disclose.

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Other Financial Industry Activities and Affiliations Alexander Capital Advisors, LLC and its management persons are not registered as a broker‐dealer or representative of a broker‐dealer and do not have any applications pending to register as a broker‐dealer or as a representative of a broker‐dealer. Alexander Capital Advisors, LLC and its management persons are not registered, nor have an application pending to register, as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. As described previously in Item 6 ‐ Portfolio Manager Selection and Evaluation, Alexander Capital Advisors, LLC serves as General Partner to a private investment limited partnership known as The Plato Fund L.P. (the Fund). Alexander Capital Advisors, LLC and The Plato Fund, L.P. are under common control of Thomas F. Paolozzi III, President, and Chief Compliance Officer. Alexander Capital Advisors, LLC provides investment advice to the Fund and offers advice to Clients on the advisability of investing in the Fund. The nature of the conflict of interest resulting from this arrangement is further elaborated in Item 6 – Portfolio Manager Selection and Evaluation, as well as the steps taken by the Firm to address those conflicts. Alexander Capital Advisors, LLC does not recommend or select other investment advisers for its Clients, nor does it have any other business relationships with other investment advisers. B. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Alexander Capital Advisors, LLC has adopted a Code of Ethics that sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Our Code of Ethics also includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by our covered persons. The code also includes oversight, enforcement and recordkeeping provisions. A copy of Alexander Capital Advisors, LLC’s Code of Ethics is available to our advisory Clients or any prospective Client upon request to Thomas F. Paolozzi III at our principal address. Alexander Capital Advisors, LLC recommends to Clients that they buy or sell securities in which we have some financial interest. Specifically, as described in Item 6 – Portfolio Manager Selection and Evaluation previously, Alexander Capital Advisors, LLC acts as the General Partner to a private investment limited partnership known as The Plato Fund, L.P. and offers advice to its Clients on the advisability of investing in The Plato Fund, L.P. As this represents a conflict of interest, the Firm’s Code of Ethics places limitations upon the timing of trades in the Fund relative to those in Client accounts and requires ongoing review of trades to ensure compliance with these procedures. Alexander Capital Advisors, LLC buys or sells for its related persons securities that it also recommends to Clients. The Firm places such securities on its Restricted List and prohibits the purchase or sale of Restricted Securities in The Plato Fund, L.P. on the same trading day as any transaction in that security effected for any other Client accounts. A record of all trades placed in Client accounts, including The Plato Fund, is reviewed Quarterly to ensure adherence to these procedures. C. Review of Accounts. Account reviews are conducted on an ongoing basis by Thomas F. Paolozzi III, President. All Clients are advised that it remains their responsibility to advise us of any changes in their

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investment objectives and/or financial situation. All Clients are encouraged to review investment objectives and account performance with the Firm on an annual basis. Accounts are reviewed following material deposits or withdrawals. Accounts may also be reviewed in conjunction with the purchase or sale of a position across all Client accounts. Clients are provided with transaction confirmation notices and monthly account statements directly from the custodian. Clients also receive a quarterly report from Alexander Capital Advisors, LLC summarizing account activity and performance. Clients are urged to compare these two reports. D. Client Referrals and Other Compensation. Alexander Capital Advisors, LLC receives an economic benefit from Schwab Advisor Services in the form of the support products and services it makes available to us and other independent investment advisors whose Clients maintain their accounts at Schwab Advisor Services. The availability to us of Schwab Advisor Services products and services is not based on us giving investment advice, such as buying securities for our Clients. Alexander Capital Advisors, LLC does not compensate any outside party for Client referrals. E. Financial Information. Alexander Capital Advisors, LLC does not require or solicit prepayment of fees more than six months in advance. Alexander Capital Advisors, LLC has discretionary authority over Client accounts. There are no financial conditions that are likely to impair our ability to meet contractual commitments to Clients. Alexander Capital Advisors, LLC has never been the subject of a bankruptcy petition at any time.

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