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St. James INVESTMENT ADVISORSALL CAP EQUITY PORTFOLIO

ST. JAMES INVESTMENT ADVISORS1MARGIN OF SAFTEY “Confronted with the challenge to distill the secret of soundinvestment into three words, we venture the motto, MARGIN OF SAFTEY.”-Benjamin Graham, The Intelligent InvestorALL CAP EQUITY PORTFOLIOThe St. James All Cap Equity Portfolio seeks long-term capital appreciation through an actively managed portfolio of companies with sustainable competitive advantages and consistent strong business performance.The portfolio will consist of approximately 30 to 35 holdings and is balanced amongst market capitalizations, sectors, and industries.We emphasize “All-Weather Businesses.”St. James employs a disciplined investment strategy by identifying high quality companies at what it believes to be attractive prices.We focus on essential companies in today’s economy but notably on companies we believe will be just as relevant in five to seven years. Exceptional business performance combined with endurance!

OBJECTIVES and why considerST. JAMES INVESTMENT ADVISORS2• We invest in quality companies with strong cash flow above operating needs. Maintain competitive advantages over the long-term by reinvesting back into their business to maintain and improve their competitive advantages!• Exceptional Return on Shareholder Equity Measures how many dollars of profit are generated for each dollar of shareholder equity. How well is a company utilizing its equity to generate profits? We target companies that have a return on equity greater than 15% and we believe will maintain or grow during the next five to seven years.• Under normal circumstances, at least 95% of the portfolio assets will be invested in equity securities selected through a thoughtful value-oriented approach.

ST. JAMES INVESTMENT ADVISORSST. JAMES INVESTMENT ADVISORSST. JAMES INVESTMENT ADVISORSST. JAMES INVESTMENT ADVISORS33INVESTMENT philosophy• We believe our philosophy is a rational and intelligent approach to investing: we buy pieces of companies which we have a good understanding of at prices below our fair value assessment.• We approach investing in publicly-traded companies on a long-term basis as if we were buying the company outright and retaining current management.• Our goal is to provide superior long-term returns for investors while attempting to minimize risk.• We seek absolute returns while attempting to outperform the S&P 500 index over the long-term.

ST. JAMES INVESTMENT ADVISORSST. JAMES INVESTMENT ADVISORS44BUY A BUSINESS, NOT A STOCKSTOCK SELECTION CRITERIA We approach investing in publicly traded companies as if we were buying the company and current management. • Think about investing as the purchase of a business. Watch the business, not the stock! • Utilize a sufficiently long-term time frame. If you had to hold a purchased business for five to seven years, what would it look like? • Acknowledge volatility does not equal risk. Price is what one pays, but value is what one gets. • We buy partial ownership of companies in which we understand at prices below their intrinsic value. Is the company’s stock attractively priced? Is there a margin of safety?

ST. JAMES INVESTMENT ADVISORS5ST. JAMES INVESTMENT ADVISORS6QUALIFICATIONSELL DISCIPLINEPATIENCEFUNDAMENTAL ANALYSIS &DETERMINING FAIR VALUESTAGES STAGES QUALIFICATIONQUALIFICATIONSTAGES QUALIFICATIONQUALIFICATIONSELL DISCIPLINESELL DISCIPLINESTAGES SELL DISCIPLINESELL DISCIPLINEPATIENCEPATIENCESTAGES PATIENCEPATIENCEFUNDAMENTAL ANALYSIS &FUNDAMENTAL ANALYSIS &STAGES FUNDAMENTAL ANALYSIS &FUNDAMENTAL ANALYSIS &DETERMINING FAIR VALUEDETERMINING FAIR VALUESTAGES DETERMINING FAIR VALUEDETERMINING FAIR VALUEINVESTMENT PROCESS

ST. JAMES INVESTMENT ADVISORS6INVESTMENT PROCESS STAGE 1 QUALIFICATIONIdenfy OpportuniesMarket Cap > $5 BillionScreen for companies withone or more of the followingCharacteriscs: good business, shareholder-oriented managementor low purchase priceFollowedOpportunity

ST. JAMES INVESTMENT ADVISORS7STAGE 2 INVESTMENT PROCESS FUNDAMENTAL ANALYSIS & DETERMINING FAIR VALUEQuality Business Strong Cash Flow Aracve BusinessStrong ManagementCapable Operators?Shareholder Oriented?Proper Incenves?Substutes?Exisng Competors?New Competors?Pricing Power?Power of Suppliers?Compeve Advantages?Are They Sustainable?Weather All Economic Climates?Return on Shareholder Equity“Sum of the Parts”AnalysisDiscounted Cash Flow AnalysisGraham’s “Margin of Safety”Definion

ST. JAMES INVESTMENT ADVISORS8STAGE 3 INVESTMENT PROCESS PATIENCEAssess and Monitor Fair Value – We seek to initiate positions at a discount to our fair value determination.Risk control – We define “risk” as the probability of the permanent loss of capital, not price volatility. We believe in concentrating our portfolio in the most attractive investment ideas, which can cause short-term price volatility. A portfolio of approximately 30 to 35 companies permits ample diversification while allowing our best ideas to have the most significant positive impact on performance. It is important to note that no one company accounts for more than 7% of the portfolio assets on the cost side; and no one industry group accounts for more than 30% of the portfolio's value on the cost side.

ST. JAMES INVESTMENT ADVISORS9STAGE 4 INVESTMENT PROCESS SELL DISCIPLINEPrice Appreciation -The price reaches our appraisal and no margin of safety remains. Superior Risk / Reward Elsewhere -We can improve our risk/return profile substantially. For example, we can replace a business selling at 90% of its worth with an equally attractive company trading at 50% of its value. Eroding Fundamentals - The future earnings power of the company becomes severely impaired by competitive threats, balance sheet deterioration, or poor capital allocation.Loss of Confidence in Management -We no longer believe management can build shareholder value and efforts to find new corporate leadership would be unsuccessful or too costly.

ST. JAMES INVESTMENT ADVISORS10St. James Investment Advisors is an independent, fee-only,U.S. Securities and Exchange Commission registered investment advisory firm, providing customized portfolio management services to individuals and their financial advisors.Our investment methodology blends a combination of fundamental analysis, discipline and patience with the goal of creating long-term returns based on the time-proven principles of value investing. We are professional portfolio managers Committed to Value Investing and our sole focus as a firm is to manage private investment accounts for individuals and their financial advisors throughout the United States.